Privacy Policy

1. Introduction

First Source World Pty Ltd ("FSW", "we", "us", or "our") operates the FSW Learn eLearning platform (the "Platform"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform.

We are committed to protecting your personal information and your right to privacy. We comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and the General Data Protection Regulation (GDPR) where applicable.

2. Information We Collect

2.1 Personal Information

We may collect personal information that you provide directly to us, including:

• Account Information: Name, email address, phone number, date of birth, and profile details
• Educational Information: Student ID, institution name, courses enrolled, grades, and certificates earned
• Payment Information: Billing address, payment method details (processed securely by third-party payment processors)
• Communication Data: Messages, feedback, and support requests you send to us
• Organization Data: For organization administrators, we collect organization name, address, and billing contact information

2.2 Automatically Collected Information

When you access the Platform, we automatically collect:

• Usage Data: Pages visited, time spent on pages, links clicked, and interaction patterns
• Device Information: Browser type, operating system, device type, and screen resolution
• Log Data: IP address, access times, and referring URL
• Course Progress: Lessons completed, quiz attempts, assessment submissions, and learning progress

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, maintain, and improve our educational services
• To create and manage your account and user profile
• To process enrollments and track course progress
• To generate and verify certificates
• To communicate with you about courses, updates, and promotional materials (with your consent)
• To respond to your comments, questions, and requests
• To monitor and analyze trends, usage, and activities
• To detect, investigate, and prevent fraudulent transactions and abuse
• To comply with legal obligations and resolve disputes

4. Legal Basis for Processing (GDPR)

Where GDPR applies, we process your personal information based on:

• Contractual Necessity: Processing is necessary to perform a contract with you
• Legitimate Interests: Processing is necessary for our legitimate business interests
• Consent: You have given consent for specific purposes (e.g., marketing communications)
• Legal Obligation: Processing is necessary to comply with legal obligations

5. Information Sharing and Disclosure

We do not sell your personal information. We may share your information with:

• Educational Institutions: Progress reports and enrollment data may be shared with the organization you are enrolled under
• Instructors: Course instructors may access student progress and submission data for their courses
• Service Providers: Third-party vendors who assist us in operating the Platform (payment processors, cloud hosting, email services)
• Legal Requirements: When required by law or to protect our rights and safety
• Business Transfers: In connection with a merger, acquisition, or sale of assets

6. Multi-Tenancy Data Separation

FSW Learn is a multi-tenant platform where each organization operates in an isolated environment. Your data is segregated by organization, and users from one organization cannot access data from another organization unless explicitly authorized.

Organization administrators have access to user data within their organization for management and reporting purposes.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (HTTPS/TLS) and at rest
• Role-based access controls and authentication
• Regular security assessments and vulnerability testing
• Secure backup and disaster recovery procedures
• Staff training on data protection practices

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

8. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services to you
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Maintain accurate educational records for certificate verification

Certificate records are retained indefinitely for verification purposes. Upon account deletion, we will anonymize or delete your personal information within 90 days, except where retention is required by law.

9. Your Rights and Choices

Depending on your location, you may have the following rights:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal exceptions)
• Portability: Request a portable copy of your data in a structured format
• Objection: Object to processing based on legitimate interests
• Withdrawal of Consent: Withdraw consent where processing is based on consent
• Marketing Opt-out: Opt out of receiving marketing communications at any time

To exercise these rights, please contact us using the details provided below. We will respond to your request within 30 days.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and store information about your preferences and activity on the Platform. We use:

• Essential Cookies: Required for the Platform to function (authentication, session management)
• Preference Cookies: Remember your settings and preferences (theme, language)
• Analytics Cookies: Help us understand how users interact with the Platform

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality.

11. Third-Party Links and Services

The Platform may contain links to third-party websites and services (e.g., embedded videos, external resources). We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

12. Children's Privacy

Our Platform is intended for users aged 13 and above. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly.

Educational institutions enrolling students under 18 are responsible for obtaining appropriate parental or guardian consent.

13. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place, such as standard contractual clauses or adequacy decisions, to protect your information in accordance with this Privacy Policy.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

15. Contact Us

If you have questions or concerns about this Privacy Policy or wish to exercise your rights, please contact our Privacy Officer:

For complaints about our handling of your personal information, you may also contact the Office of the Australian Information Commissioner (OAIC) or your local data protection authority.