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Privacy Policy

How Klayo collects, uses, and protects your personal information.

1. Introduction

The “ACI Online Learning Centre”, “Canadian Airports Online College”, “Duty Free World Council Academy” and “Klayo” are services operated by Ceventas Pty Ltd (ABN 66 128 878 811).

This Privacy Policy applies to all personal information collected as a result of your participation in services provided by Ceventas.

We may make alterations or additions to this policy from time to time. Should we do so, we will update this policy on our web site.

We require that all our customers and users agree to abide by our Privacy Policy as part of our terms and conditions.

2. What is “personal information”?

The Privacy Act 1988 (Cth) (Act) defines “personal information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:

  1. whether the information or opinion is true or not; and
  2. whether the information or opinion is recorded in a material form or not.

If information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this privacy policy.

3. Purpose of collection

Depending on how you use our services, your interactions with us and the reasons for which you provide any information, your personal information may be used for the following purposes:

  1. to ensure that our services are presented to you in an effective manner;
  2. to provide you with information that you have requested from us; and
  3. where you have asked us to or consented to us sending you in electronic and/or paper form promotional materials about our services (such as newsletters or other marketing material), unless you tell us not to do so.

We will only use personal information where it is lawful to do so in connection with our normal business activity. Typically, we will use it:

  1. because it is necessary to fulfil a request you have made as an existing or prospective customer relating to the provision of our services;
  2. because you have provided your express or implied consent; or
  3. because it is in our legitimate interests to explain and promote our services.

4. What information do we collect?

Ceventas collects different information about you at different times. There are two broad categories of information that we collect from you:

Information we require to supply our services

When you sign up for Ceventas services, or when you make an inquiry about our services, we may request personal information such as your name, company, seniority, position, address, telephone number, email address and credit card details (if you are paying online).

Personal information stored on our systems

Ceventas, its service providers and data processors will have personal information stored on our systems due to the nature of the services we provide.

This information may include training records and competency attributes including knowledge, skills, abilities, competencies and other relevant workforce capability data.

This information will be kept strictly confidential, unless we are required to release the information by law.

Personal information is only retained on Ceventas systems for as long as it is required in connection with the original reason for collection. When no longer required, it is either deleted or deidentified.

5. How we collect your personal information

The only information we collect is what you provide to us or which you have, expressly or by implication, agreed we can collect from authorized third parties in order to enable your participation in the services we offer.

By participating in Ceventas services and by voluntarily providing us with information about yourself, you are consenting to our use of that data in the manner described in this policy.

You may withdraw your consent at any time. If you do so, however, we may not be practicable or possible for you to receive Ceventas services.

6. Direct marketing

If you use our services, you consent to the receipt of direct marketing material. We will only use your personal information for this purpose if we have collected such information direct from you or from other authorized users of the service, and if the material is of a type that you would reasonably expect to receive from us.

We do not use sensitive personal information in direct marketing activity. Our direct marketing material will include a simple means by which you can opt out of receiving further communications of this nature.

In the case of electronic marketing material subject to the Spam Act 2003 (Cth), the material will be accompanied by a functional unsubscribe facility.

An alternative means of opting out is to contact us as set out below and simply request that you receive no further such communications.

We may use your personal information to:

  1. Contact you in relation to upgrading your use of our services, communicating special offers (from us, or on behalf of third parties), providing newsletters or conducting surveys, and individual service audits.

We may give extracts of our customer lists containing personal information to third party contractors to do this on our behalf. We will ensure that those contractors are bound to protect your personal information to the same standard that we are.

  1. Identify the source of new customers for Ceventas
  2. Monitor and address complaints and other feedback, and to resolve disputes
  3. In the case of credit cards, to bill you for services
  4. Maintain a technical and account history of your dealings with us, and to re-establish your account with us where you rejoin as a customer within six months after having terminated your account
  5. Monitor your compliance with our Terms of Use and other terms and conditions of our service

Ceventas uses the services of HubSpot and as such personal data will be transferred and processed by HubSpot when consent to receive promotional material is given.

We will disclose your personal information, without notice or your consent, only if:

  1. We are required to do so by law or in the good faith belief that such action is necessary to conform with the laws, applicable code of conduct or legal process relevant to our services.
  2. To protect and defend the rights or property of the Ceventas.
  3. If we consider it necessary to do so, in order to enforce or apply the terms of any of our agreements with you
  4. If we sell our business or part of it
  5. In extreme circumstances, to protect the personal safety of users of the Ceventas services, our staff or the public
  6. If you graduate from the Airport Operations Diploma Program (AODP) or the Certificate in Airside Safety, your name and airport may appear in Ceventas communication channels.

7. Cookies

If we collect personal information from you via our services and websites, we may use digital cookies to remember your preferences and collect online traffic data and browsing characteristics.

This information is statistical data about our users’ browsing patterns and is used to understand how the website or service is being used.

Internet cookies are small strings of text placed on users’ hard drive during the data exchange that happens when a browser points to a website. The browser stores the message in a text file which is sent back to the server each time the browser requests a page from the server.

Cookies and other information collection technologies can only store information that is explicitly provided by the user or visitor in the first place, or information which is already known to the website such as your IP address.

You can choose to adjust your browser to reject cookies or to notify you when they are being used, bearing in mind that rejecting cookies may mean you may be unable to access a service.

By using our services and websites without adjusting your browser, however, you agree that we can store and access the above cookies on your device.

You may also be shown a cookie consent pop-up when you first access the site. Your preferences will be recorded and you do not need to adjust via your browser.

8. Disclosure of personal information

By using our service’s you agree that your employer and/or airports at which you work may have access to your training records including courses enrolled, completion status, dates of enrolment and completion and your final assessment scores.

Your personal information may be accessible by other authorised users of the service such as training and compliance managers. Your information will not be available to anyone who is not an authorised registered user of the service.

We may have cause to disclose personal information to our service providers who assist us in operating our computer systems. Your personal information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties. In the event that we outsource part of our infrastructure, it is possible that the entity we engage for this purpose may also have access to your personal information.

We generally do not share personal information collected via the website with third parties unless one of the following circumstances applies:

  1. you have consented to us doing so;
  2. we are under a legal or regulatory obligation to disclose the information;
  3. our company, or substantially all our company’s assets, are merged or acquired by a third party, in which case your personal information may form part of the transferred or merged assets;
  4. to provide anonymous statistical information about users of the website and related usage information to reputable third parties;
  5. part of our infrastructure is outsourced; or
  6. we are using a third party service provider to provide services that involve data processing (for example, hosting the website).

Subject to the foregoing, we only use your personal information in a manner consistent with the original purposes of collection or as otherwise permitted by the Australian Privacy Principles (or, where and to the extent applicable, the GDPR or any other applicable privacy or data protection legislation).

9. Access and correction

For services to which you have personally subscribed, you can access and (where appropriate) correct personal information which you have provided to us.

For services to which your employer has subscribed, the responsibility for management of your employment records rests with you and your employer, not with us, and any enquiries regarding such records should be directed to your employer.

Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions. If you require assistance in accessing your personal data for this purpose, please contact us as set out below.

10. Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below.

All complaints will be carefully considered, and we may seek further information from you to clarify your concerns.

If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem.

If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

11. Overseas transfer

Ceventas services are operated on a global basis. Your personal information may be transferred overseas or stored overseas for a variety of reasons.

By the very nature of our services, it is a condition of participation that you consent to the overseas transfer of your personal information.

If your personal information is sent to a recipient in a country with data protection laws which are at least substantially similar to the Australian Privacy Principles, and where there are mechanisms available to you to enforce protection of your personal information under that overseas law, we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled in that jurisdiction.

If your personal information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia’s, we will take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Australian Privacy Principles.

You indicate your consent to the overseas transfer of your personal information by participating in our services.

If you do not consent, we may be unable to provide you with the services.

12. GDPR and other foreign legislation

In some circumstances, the European Union General Data Protection Regulation (“EU GDPR”) provides additional protection to individuals located in Europe.

Similarly, individuals located in the United Kingdom will in some circumstances be protected by domestic legislation which effectively implements the GDPR (“UK GDPR”).

Where this is the case, there may be additional rights and remedies available to you under the GDPR in the event that your personal information is handled in a manner inconsistent with that law.

In these circumstances, your additional rights will include the right to object to, restrict and/or withdraw your consent to the processing of your personal information, the right to access or erase your personal information, and the ability to receive a machine-readable copy of your personal information.

Some countries outside the EU or the UK may also have data protection legislation with extra-territorial effect.

To the extent relevant, your personal information is handled in a manner consistent with that law.

Please contact us at [email address] if you require any further explanation in this regard.

13. Amendments to this policy

We reserve the right to change and modify this privacy policy at any time without prior notice. Your continued use of our services following the posting on our website of changes to these terms means you accept these changes.

14. How to contact us about privacy

If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us on support@klayo.com.

15. Other important information about our services

In addition to the privacy issues outlined above, you should note the following:

  1. we endeavour to keep the our services and websites accurate, up to date and available at all times. However, we disclaim all responsibility and liability, to the extent permitted by law, regarding the accuracy and/or availability of the material.
  2. the intellectual property rights in all materials related to our services and websites are owned by or licensed to Ceventas Pty Ltd, including, without limitation, those subsisting in all photos, graphical works and text (including publications). You may reproduce such materials for your personal review only. You may also copy materials on this website to others provided that any such copy is accurate and not misleading, is provided free of charge, and acknowledges Klayo as its source;
  3. any materials related to our services and websites are for information purposes only, and to the fullest extent permitted by law, we disclaim all liability and responsibility for any reliance on the materials on our site; and
  4. any links provided by our services and websites to any third party sites are provided for information purposes only. We are not responsible for the content, and have no control over, the third party sites to which we provide links.