BEST BRAINS AUSTRALIA PRIVACY POLICY
1. About this Privacy Policy
BEST BRAINS OF AUSTRALIA PVT LTD, trading as Best Brains Australia ("Best Brains", "we", "us" or "our"), respects your privacy and is committed to protecting the personal information entrusted to us.
This Privacy Policy explains how we collect, hold, use, disclose, secure, retain and otherwise handle personal information in connection with:
- Our Australian corporate website and related webpages
- Online enquiry, contact and registration forms
- Placement testing and enrolment enquiries
- Educational programs, learning platforms and support services administered by Best Brains
- Marketing campaigns, events, competitions and promotions
- Franchise enquiries, franchise support and corporate operations
- Employment and contractor applications
- Communications with parents, guardians, students, prospective customers, franchisees, employees, contractors, suppliers and other individuals
- Any other Australian service that refers to this Privacy Policy.
We are committed to complying with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), the Notifiable Data Breaches Scheme, and other applicable Australian privacy, health-information, electronic-marketing, and data-protection laws.
2. Best Brains Corporate Offices and Independently Owned Centers
Best Brains operates through a network that may include independently owned and operated franchise learning centers.
A Best Brains franchisee is generally a separate legal entity from the Australian corporate office. Each franchisee is responsible for its own conduct and for the personal information it independently collects, holds, uses or discloses.
When you submit an enquiry through the Best Brains corporate website, we may provide your information to the Best Brains learning center that is closest to you, that you select, or that is otherwise best placed to respond to your enquiry.
In these circumstances:
- Best Brains corporate may retain and handle a copy of your information under this Privacy Policy
- The selected franchisee may separately collect and handle your information
- The franchisee may have its own privacy policy and privacy contact
- Questions concerning a franchisee's handling of information should generally be directed to that franchisee in the first instance.
Nothing in this section limits any responsibility that Best Brains corporate may have under applicable law for its own handling of personal information.
3. Meaning of Personal Information
"Personal information" generally means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true or recorded in a material form.
"Sensitive information" is a category of personal information that receives additional protection. It can include information about a person's health, disability, racial or ethnic origin, religious beliefs, biometric information, and certain other personal characteristics.
"Health information" may include information about a person's physical or mental health, disability, allergies, medical conditions, health services, medications, or support requirements.
4. Personal Information We May Collect
The information we collect depends on how you interact with us.
4.1 Parent and Guardian Information
We may collect:
- Full name
- Postal or residential address
- Email address
- Telephone number
- Relationship to a student
- Emergency contact details
- Preferred learning center
- Communications and enquiry history
- Account login details
- Billing and transaction information
- Program preferences
- Marketing preferences
- Identification information where reasonably required to verify authority or respond to an access request.
4.2 Student and Child Information
We may collect information including:
- Name
- Date of birth or age
- Gender, where reasonably necessary and voluntarily provided
- School, year level or grade
- Parent or guardian details
- Preferred learning center
- Subjects and programs selected
- Placement test results
- Assessment responses and scores
- Educational level and learning needs
- Attendance and absence records
- Homework, classwork and academic progress
- Teacher observations and instructional notes
- Learning platform usage
- Student account information
- Photographs, audio or video recordings where appropriate consent has been obtained
- Emergency contact information
- Health, disability, allergies, medical or learning support information where reasonably necessary.
We do not intentionally collect more information about a child than is reasonably necessary for the relevant educational, safety, administrative, or legal purpose.
4.3 Health and Sensitive Information
Where reasonably necessary, we may collect sensitive information such as:
- Allergies or medical conditions relevant to student safety
- Disability or accessibility requirements
- Learning difficulties or educational support needs
- Emergency medical information
- Dietary or religious requirements relevant to an activity
- Other information needed to provide appropriate accommodations or respond to an emergency.
We generally collect sensitive information with consent, or where its collection is otherwise authorised or required by law.
4.4 Website and Technical Information
When you use our website, applications or online services, we may automatically collect:
- IP address
- Device type
- Browser type and version
- Operating system
- Approximate location derived from an IP address
- Referring website
- Pages viewed
- Links selected
- Date and time of access
- Session duration
- Cookie and similar technology identifiers
- Advertising identifiers
- Website interaction data
- Application activity
- Error, crash and diagnostic information
- Information used to detect fraud, misuse, or security threats.
4.5 Enquiry, Enrolment and Payment Information
We may collect:
- The programs or subjects in which you are interested
- Requested placement test or appointment dates
- Enrolment status
- Promotional codes
- Payment status
- Invoices, refunds and transaction records
- Limited payment information
- Communications concerning payments or enrolment.
Payment card information may be collected directly by a third-party payment processor. Where this occurs, Best Brains may receive confirmation of the payment and limited transaction details without receiving or storing the complete payment card number.
4.6 Marketing, Event and Media Information
We may collect:
- Email and SMS subscription information
- Promotion and competition entries
- Event registrations
- Survey responses
- Reviews and testimonials
- Social media interactions
- Photographs and recordings from corporate events
- Marketing consent records.
We will seek additional consent before using an identifiable student's image, recording, testimonial or academic achievement for promotional purposes unless the use is otherwise authorised by law.
4.7 Franchise Enquiries and Franchise Network Information
If you enquire about purchasing or operating a Best Brains franchise, we may collect:
- Identity and contact information
- Employment and business experience
- Professional qualifications
- Financial capacity information
- Proposed business locations
- Corporate or business records
- References
- Application and interview information
- Information required for due diligence, training, compliance, and ongoing franchise support.
4.8 Employment and Contractor Information
We may collect information from job applicants, employees and contractors, including:
- Resumes and employment history
- Qualifications and certifications
- References
- Background screening information, where lawful
- Working-with-children or similar clearance information
- Right-to-work information
- Interview notes
- Payroll and tax information
- Performance and training information
- Workplace communications.
Employee records may also be governed by workplace laws, contractual obligations and internal policies. Certain employee records may be subject to exemptions under the Privacy Act.
5. How We Collect Personal Information
We may collect personal information:
- Directly from you
- From a parent, guardian or authorised representative
- From a student, where appropriate for the student's age and capacity
- Through our website, applications, portals and online forms
- By telephone, email, SMS, video call or in person
- Through placement tests, assessments, registrations and enrolments
- Through independently owned Best Brains franchisees
- From schools, teachers or support professionals where you have authorised the disclosure
- From event, marketing, referral or lead-generation partners
- From payment processors and technology providers
- From recruitment agencies and referees
- From publicly available sources
- Through cookies, pixels, analytics tools and similar technologies
- Where authorised or required by law.
Where practical, we will collect personal information directly from the individual concerned or from the individual's parent, guardian or authorised representative.
If we receive unsolicited personal information, we will determine whether we could lawfully have collected it. If not, we will take reasonable steps to destroy or de-identify it, unless we are required or permitted to retain it.
6. Why We Collect and Use Personal Information
We may collect, hold, use and disclose personal information to:
- Respond to enquiries
- Identify an appropriate Best Brains center
- Arrange placement tests, consultations and appointments
- Assess a student's educational level and learning needs
- Recommend educational programs or starting levels
- Enroll students and administer educational services
- Create and manage parent, student, franchisee or staff accounts
- Deliver classes, homework, assessments and learning support
- Monitor educational progress and service quality
- Communicate with parents, guardians and students
- Manage attendance, absences, make-up classes and scheduling
- Support student health, safety and wellbeing
- Accommodate disabilities or learning-support requirements
- Respond to emergencies
- Process payments, invoices and refunds
- Administer promotions, competitions and events
- Provide technical support
- Prevent fraud, misuse, unauthorised access and cybersecurity incidents
- Operate, maintain and improve our websites, applications and systems
- Conduct analytics, research and service development
- Train staff and franchisees
- Manage the Best Brains franchise network
- Assess franchise applications and provide franchise support
- Recruit and manage employees and contractors
- Obtain professional, legal, accounting, insurance or technology services
- Send marketing communications where permitted
- Maintain business and taxation records
- Investigate complaints and disputes
- Protect our legal rights and the rights and safety of others
- Comply with child-safety, education, taxation, employment and other legal obligations
- Comply with lawful requests from courts, regulators, law enforcement bodies and government authorities.
We may also use de-identified or aggregated information for statistical analysis, curriculum development, business planning, reporting and service improvement where the information no longer reasonably identifies an individual.
7. Children and Young People
Because Best Brains provides services to children, we take additional care when handling children's personal information.
A parent or guardian will generally be asked to provide consent or authorisation where a child does not have sufficient maturity and understanding to make the relevant privacy decision.
Where appropriate, we may also:
- Explain privacy practices in age-appropriate language
- Seek the child's agreement in addition to parental consent
- Consider the child's maturity, understanding and best interests
- Limit the collection of a child's information
- Provide parents or guardians with access to relevant information
- Recognise that an older or sufficiently mature child may be able to make certain privacy decisions independently
- Restrict access where disclosure could create a serious safety risk or where otherwise required by law.
8. Cookies and Similar Technologies
Our websites and online services may use cookies, local storage, pixels, tags, software development kits and similar technologies.
These technologies may be used for:
- Website functionality
- User authentication
- Security and fraud prevention
- Remembering preferences
- Analytics
- Performance measurement
- Advertising and campaign measurement
- Embedded media
- Social-media functionality.
Where required, we will obtain consent before using non-essential cookies.
You may change your cookie preferences through our cookie settings or by adjusting your browser settings. Blocking certain cookies may affect website functionality.
9. Direct Marketing
Where permitted by law, we may send information regarding:
- Educational programs
- Placement testing
- Center openings
- Events
- Newsletters
- Competitions
- Special promotions
- Franchise opportunities.
You may opt out of marketing communications at any time by:
- Selecting the unsubscribe link in an email
- Updating your communication preferences
- Contacting us directly
- Following the opt-out instructions included in the communication.
Administrative, educational, billing, security, safety and legal communications are not marketing communications and may continue where necessary.
10. Disclosure of Personal Information
We may disclose personal information where reasonably necessary for the purposes described in this Privacy Policy.
10.1 Best Brains Corporate Entities
We may disclose personal information to Best Brains corporate entities for:
- Technology and platform support
- Administrative services
- Curriculum development
- Customer support
- Marketing administration
- Franchise management
- Compliance, legal and business operations.
10.2 Franchise Learning Centers
Where you request information from, or enroll with, a Best Brains learning center, we may disclose relevant information to that center.
The learning center may handle your personal information under its own privacy policy and legal obligations.
10.3 Service Providers
We may disclose personal information to carefully selected service providers that assist us with:
- Cloud hosting
- Website operation
- Learning platforms
- Payment processing
- Email and SMS delivery
- Analytics
- Cybersecurity
- Accounting
- Legal services
- Marketing support
- Customer relationship management
- Document management
- Technical support.
Service providers are required to protect personal information and use it only for authorised purposes.
10.4 Professional Advisers
We may disclose personal information to lawyers, accountants, auditors, insurers, financial advisers and other professional advisers where reasonably necessary.
10.5 Legal and Regulatory Authorities
We may disclose personal information where required or authorised by law, including to:
- Australian courts and tribunals
- Law enforcement agencies
- Government departments
- Education authorities
- Child protection agencies
- Taxation authorities
- Regulatory authorities
- Other competent public authorities.
We may also disclose information where necessary to establish, exercise or defend legal claims or protect individuals, property or systems.
10.6 Corporate Transactions
Personal information may be disclosed in connection with:
- A merger
- Acquisition
- Investment
- Business restructuring
- Sale of assets
- Transfer of operations
- Administration or insolvency proceedings.
Recipients will be required to protect personal information in accordance with applicable legal obligations.
11. Overseas Disclosure
Best Brains may disclose personal information to service providers or corporate entities located outside Australia where reasonably necessary to provide services or support our operations.
Before making an overseas disclosure, we will take reasonable steps to ensure that the recipient handles the information in a manner consistent with the Australian Privacy Principles or that another lawful exception applies.
12. Retention of Personal Information
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and to comply with legal, accounting, taxation, child-safety, contractual and regulatory obligations.
Typical retention periods include:
- General enquiries: Normally up to 24 months after the last meaningful interaction.
- Educational records: For the duration of the educational relationship and an appropriate period afterwards, subject to legal requirements.
- Marketing records: Until consent is withdrawn or the information is no longer required.
- Recruitment records: Normally up to 12 months after completion of the recruitment process unless another lawful basis applies.
- Franchise enquiries: For the duration of the application process and an appropriate business-retention period.
- Financial records: For the period required by Australian taxation and accounting legislation.
- Security logs: For a limited period necessary for operational and security purposes.
When personal information is no longer required, we will securely destroy, delete or de-identify it where appropriate.
13. Security
We implement reasonable technical, physical and organisational safeguards designed to protect personal information against misuse, interference, loss, unauthorised access, modification and disclosure.
These safeguards may include:
- Role-based access controls
- Authentication and password management
- Encryption where appropriate
- Secure hosting environments
- Network monitoring
- Regular backups
- Incident-response procedures
- Employee confidentiality obligations
- Vendor security assessments
- Data-minimisation practices
- Physical security measures
- Cybersecurity monitoring.
Although we take reasonable steps to protect personal information, no internet transmission or electronic storage system can be guaranteed to be completely secure.
14. Notifiable Data Breaches
We maintain procedures for identifying, investigating, containing and responding to suspected data breaches.
Where required by the Privacy Act 1988 (Cth) and the Notifiable Data Breaches Scheme, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) where an eligible data breach is likely to result in serious harm.
Notifications will contain the information required by law and may be updated as further information becomes available.
15. Automated Decision-Making
We may use automated systems to support:
- Spam filtering
- Cybersecurity monitoring
- Website analytics
- Lead routing
- Appointment scheduling
- Educational recommendations
- Customer-service workflows
- Administrative reporting.
We do not intend to make decisions that have significant legal effects solely through automated processing without appropriate human oversight.
16. Access and Correction
You may request access to the personal information we hold about you and request correction of inaccurate, incomplete or out-of-date information, subject to applicable legal exceptions.
We may require reasonable verification of your identity before responding to your request.
Where permitted by law, we may refuse access or correction in certain circumstances and will explain the reasons for our decision where required.
17. Privacy Complaints
If you believe we have not handled your personal information appropriately, please contact us first so that we can investigate and attempt to resolve your concern.
If you remain dissatisfied, you may lodge a complaint with the:
Office of the Australian Information Commissioner (OAIC)
The OAIC is Australia's independent privacy regulator responsible for administering the Privacy Act 1988 (Cth).
18. Third-Party Websites
Our website may contain links to:
- Best Brains learning-center websites
- Payment-service providers
- Government websites
- Educational partners
- Social-media platforms
- Recruitment services
- Other third-party websites.
These websites operate independently and have their own privacy policies. We encourage you to review those privacy policies before providing personal information.
19. Social Media
If you interact with Best Brains through Facebook, Instagram, LinkedIn, YouTube, X or another social-media platform, that platform may independently collect and process your personal information in accordance with its own privacy policy.
We may receive information that you choose to make available through your privacy settings or interactions with our official pages.
20. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect:
- Changes in Australian law
- Regulatory guidance
- Technology developments
- Educational services
- Business operations
- Security practices
- Processing activities.
The latest version will be published on our website together with the revised effective or last-updated date.
Where required by law, we will provide additional notice before material changes become effective.
21. Contact Us
Questions, requests or complaints regarding this Privacy Policy may be directed to:
BEST BRAINS OF AUSTRALIA PTY LTD
Email: info@bestbrains.com
Please include sufficient information to help us identify your request and respond appropriately.
