Privacy Policy
Bolsta Education (ABN 47 502 151 620) understands the importance of protecting the privacy of an individual’s personal information.
This policy sets out how Bolsta Education aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Bolsta Education and the way Bolsta Education collects, holds, uses and discloses your personal information.
In handling your personal information, Bolsta Education complies with the Privacy Act 1988 (Cth) (Privacy Act), the 13 Australian Privacy Principles in the Privacy Act and all other relevant Australian privacy laws.
This policy may be updated from time to time.
2. What kinds of personal information does Bolsta Education collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its products and/or services, Bolsta Education may collect your personal information.
Generally, the kinds of personal information Bolsta Education collects are:
(a) contact and identification information such as your name, address, telephone number, email address, billing and shipping address or other types of verification details;
(b) where you are acting on behalf of another entity (whether as an employee, director or other representative), details of that entity and your relationship with it;
(c) financial information and other relevant information for applying for a credit account with Bolsta Education such as:
(i) your name, position, residential address, phone number and drivers license number if you are a director, partner or proprietor of a business applying for a credit account with Bolsta Education;
(ii) your name, phone number and email address if you or an entity you represent are providing a trade reference for the purposes of an individual or entity applying for a credit account with Bolsta Education;
(d) when applying for a position at Bolsta Education, information about your employment such as previous employers, resumes and referees;
(e) health information (including vaccination status information and information regarding pre employment medical checks, where applicable):
(i) where you consent to the collection of such information and if relevant to the provision of our products and/or services; or
(ii) where you are applying for a position with Bolsta Education and it is relevant to Bolsta Digital’s assessment of whether you are able to perform the inherent requirements of the particular role; and
(f) where you are a prospective, current or former employee or contractor, information about your competencies, qualifications and licenses (where applicable);
(g) information about your individual preferences for products or services;
(h) comments made by you in internet reviews and social media as well as photographs of you for Bolsta Education’s promotional purposes with your consent;
(i) where you are a guarantor on an application with Bolsta Education, relevant guarantor information;
(j) if you are an employee or contractor, information about your employment or engagement with Bolsta Education; and
(k) other information required for Bolsta Education’s functions and activities.
In some circumstances Bolsta Education may also hold other personal information provided by you.
3. How does Bolsta Education collect personal information?
Generally, Bolsta Education collects your personal information in the following ways:
(a) an entity you represent (including but not limited to your employer or a company of which you are a director), where necessary for Bolsta Education to provide its products or services to that entity through you or where necessary for that entity to supply products or services to Bolsta Digital;
(b) an information services provider;
(c) a publicly maintained record or other publicly available sources of information including social media platforms and similar websites, such as LinkedIn;
(d) if for recruitment purposes, an external recruitment, labour hire, or background screening services provider or third parties with whom you have previously worked;
(e) collection technologies, for example cookies;
(f) referees provided on employment applications;
(g) a third party who has included your details on a customer credit application form; and
(h) from trade references provided in customer credit applications.
Generally, Bolsta Education will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.
4. Why does Bolsta Education need your personal information?
Bolsta Education collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:
(a) providing Bolsta Education’s products and/or services to you (or the organisation you represent) and all associated purposes including:
(i) to fulfil a transaction requested by you;
(ii) to verify your identity and contact details;
(iii) for invoicing and/or administrative purposes, and;
(iv) to respond to any inquiries, feedback or complaints made by you;
(b) enabling Bolsta Education to promote its products and services to you;
(c) assisting Bolsta Education to maintain and improve its products and services;
(d) identifying and informing you of other products and services that may be of interest to you from Bolsta Education or selected third parties;
(e) processing and assessing employment applications for current and future positions;
(f) your employment with Bolsta Education;
(g) accounting, billing and other internal administrative purposes;
(h) assessing an application for a credit account or any other applications for an account or whether to accept an individual as a guarantor;
(i) otherwise managing Bolsta Education’s internal business operations and processes; and
(j) any other legal requirements.
Bolsta Education may also use your personal information for purposes related to the above purposes and for which you would reasonably expect Bolsta Education to do so in the circumstances, or where you have consented, or the use is otherwise in accordance with law.
Where personal information is used or disclosed, Bolsta Education takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Bolsta Digital. However, without certain information from you, Bolsta Digital may not be able to provide its products and/or services to you.
5. To whom does Bolsta Education disclose your personal information?
Bolsta Education discloses your personal information for the purpose for which Bolsta Education collects it. That is, generally, Bolsta Education will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to:
(a) third parties engaged to perform administrative or other business management functions, including service providers, shippers, delivery companies, vendors, payment processors, advertisers, and consultants;
(b) Bolsta Education’s professional advisors, HR advisors, agents, training organisations, contractors, consultants and related bodies corporate;
(c) people or entities considering acquiring an interest in Bolsta Education’s enterprise or assets;
(d) insurance providers;
(e) third parties you nominate to provide references for you including in credit account applications (including regarding your repayment history);
(f) third party providers as necessary to facilitate invoicing and payments;
(g) recruitment and labour hire agencies (as required); and
(h) regulatory bodies if and as necessary, including during audit processes.
Bolsta Education’s disclosures of your personal information to third parties are on a confidential basis and/or otherwise in accordance with law. Bolsta Education may also disclose your personal information with your consent or if disclosure is required or authorised by law.
6. Overseas disclosures
Bolsta Education is not likely to disclose any personal information to overseas recipients.
However, if Bolsta Education becomes likely to disclose personal information to any recipients located overseas, Bolsta Education will update this privacy policy regarding the likely disclosures (including, if it is practicable to do so, the countries in which such overseas recipients are likely to be located).
7. Direct marketing
Bolsta Education may collect, hold, use and disclose your personal information in order to inform you or the entity you represent of products or services offered by Bolsta Education or to facilitate business relationships. Bolsta Education markets its products and services by way of direct email and telephone contact.
You can opt-out of receiving marketing communications by contacting Bolsta Education on the contact details set out in paragraph 11 or through any opt-out mechanism contained in a marketing communication.
8. Security of your personal information
Bolsta Education takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference, and loss and from unauthorised access, modification, or disclosure.
Bolsta Education holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.
Bolsta Education will destroy or de-identify personal information in circumstances where it is no longer required, unless Bolsta Digital is otherwise required or authorised by law to retain the information.
9. Can you access and correct the personal information that Bolsta Education holds about you?
Bolsta Education takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by Bolsta Education. If at any time you would like to access or correct the personal information that Bolsta Education holds about you, or you would like more information on Bolsta Education’s approach to privacy, please contact Bolsta Education’s Privacy Compliance Officer on the details set out in paragraph 11 below.
Bolsta Education will grant access to the extent required or authorised by the Privacy Act and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
(a) you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
(b) Bolsta Education requests that you be reasonably specific about the information you require; and
(c) Bolsta Education may charge you a reasonable administration fee, which reflects the cost to Bolsta Education for providing access in accordance with your request.
Bolsta Education will endeavour to respond to your request to access or correct your personal information within 30 days from your request.
10. Cookies
When you are accessing Bolsta Education’s website, Bolsta Education uses ‘cookies’ which are small pieces of information sent from the website and stored by your browser on your computer’s hard drive. Cookies that Bolsta Education uses enable its systems to provide features of its services and allow you to visit its website without re-entering your username and/or password, personalise and improve your experience, and improve the functionality and user-friendliness of its services and monitor how its website is used through your computer.
This information is used by Bolsta Education to improve and tailor its website functionality and better understand how you interact with Bolsta Education products and services and to monitor aggregate usage and web traffic routing on its website. You can modify your browser setting by editing your browser options to reject Bolsta Education’s cookies or to prompt you before accepting a cookie. However, if a browser does not accept cookies or if you reject a cookie, some portions of Bolsta Digital’s online services may not function properly.
11. How to contact us
For further information or enquiries regarding your personal information held by Bolsta Education, or if you would like to opt-out of receiving any promotional or marketing communications, please contact Bolsta Education’s Privacy Compliance Officer at:
Jacob Shultz
Email: hello@bolsta.education
Privacy complaints
Please direct all privacy complaints to Bolsta Education’s Privacy Compliance Officer. At all times, privacy complaints:
(a) will be treated seriously;
(b) will be dealt with promptly;
(c) will be dealt with in a confidential manner; and
(d) will not affect your existing obligations or affect the commercial arrangements between you and Bolsta Education.
Bolsta Education’s Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.