Privacy Policy

1. About this Privacy Policy

Prime Academy Group is a trading name of ISO Prime Pty Ltd (ABN 40 687 000 657).

In this Privacy Policy, Prime Academy Group, Prime ACG, we, us and our refer to ISO Prime Pty Ltd trading as Prime Academy Group.

We provide online education, professional training, learning management system services, AI-assisted course creation, ready-made training courses, free training, organisational learning management, learner administration, assessments, certificates and related digital services.

This Privacy Policy explains how we collect, hold, use, disclose, protect and manage personal information in connection with:

• primeacg.com;
• primeacg.com.au;
• training.primeacg.com;
• our learning management system;
• our AI-assisted course creation functionality;
• individual and organisational learner accounts;
• free and paid courses;
• subscriptions;
• certificate and credential verification;
• enquiries, registrations and support requests; and
• other services operated under the Prime Academy Group brand.

We are committed to managing personal information transparently, responsibly and securely and, where applicable, in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

We may also adopt privacy protections consistent with the APPs where we are not legally required to do so.

2. What Is Personal Information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Depending on how you interact with Prime Academy Group, we may collect information including your identity, contact information, account information, learning records and information generated through your use of our platform.

Some information may constitute sensitive information under Australian privacy law. We seek to minimise the collection of sensitive information and only collect it where reasonably necessary, appropriately authorised or otherwise permitted by law.

3. Personal Information We May Collect

3.1 Identity and Contact Information

We may collect:

• first name;
• last name;
• email address;
• telephone or mobile number;
• postal or business address;
• organisation or employer;
• position or job title;
• professional information; and
• other contact details you voluntarily provide.

3.2 Account Information

When an account is created, we may collect or generate:

• username;
• account identifier;
• password or authentication information;
• user role;
• organisation membership;
• account permissions;
• enrolment status;
• subscription type;
• learner profile information; and
• account activity.

Passwords should be stored using appropriate technical security controls and should not be available to Prime Academy Group personnel in plain-text form where the relevant system supports secure credential management.

3.3 Learning and Training Information

When you participate in training, we may collect and retain:

• courses enrolled in;
• course commencement and completion dates;
• module progress;
• training activity;
• quiz results;
• assessment results;
• number of assessment attempts;
• completion status;
• course duration or learning hours;
• certificates issued;
• certificate numbers;
• certificate validity or expiry dates where applicable;
• credential verification records;
• training history; and
• other learning and competency-related records.

Where you participate through an organisation, relevant training information may also be available to authorised administrators of that organisation.

3.4 Organisational and Corporate Account Information

For organisational customers, we may collect:

• business name;
• ABN or other registration information;
• contact persons;
• billing contacts;
• administrator details;
• employee or learner lists;
• organisational structure;
• course assignments;
• team information;
• training records;
• compliance information;
• subscription information; and
• other information required to administer the organisation's learning environment.

3.5 Course Creation and Uploaded Content

Customers may upload information to Prime Academy Group to develop or administer training, including:

• policies;
• procedures;
• work instructions;
• manuals;
• presentations;
• training documents;
• guidance material;
• templates;
• images;
• videos;
• audio;
• organisational documents;
• regulatory or compliance documents; and
• other source materials.

We refer to these materials as Customer Content.

Customers should take reasonable steps to remove unnecessary personal or sensitive information from Customer Content before uploading it.

You must not upload personal information about another person unless you have appropriate authority, consent or another lawful basis to do so.

Where practical, documents should be de-identified before being uploaded for AI-assisted processing.

4. Information Collected Automatically

When you use our websites or platform, certain technical information may be collected automatically, including:

• Internet Protocol address;
• browser type;
• device type;
• operating system;
• date and time of access;
• pages or platform features accessed;
• referring pages;
• session information;
• approximate geographic region;
• login activity;
• platform usage;
• system events;
• error logs; and
• security information.

This information may be used for security, system administration, troubleshooting, analytics, service improvement and fraud prevention.

5. Cookies and Similar Technologies

Prime Academy Group may use cookies and similar technologies to:

• maintain login sessions;
• remember preferences;
• provide platform functionality;
• understand website usage;
• measure performance;
• improve user experience;
• identify technical issues;
• protect accounts and systems; and
• support analytics.

Where required, users will be given appropriate information or choices regarding non-essential cookies.

Browser settings may allow users to reject or delete certain cookies. Disabling essential cookies may affect platform functionality.

6. How We Collect Personal Information

We may collect personal information directly from you when you:

• register for a course;
• create an account;
• request free training;
• purchase a course;
• subscribe to the platform;
• complete an enquiry form;
• contact us;
• participate in training;
• undertake quizzes or assessments;
• download resources;
• request support;
• upload content;
• communicate with our chatbot;
• subscribe to communications; or
• otherwise interact with Prime Academy Group.

We may also receive information from:

• your employer;
• an organisation that enrols you;
• an authorised organisational administrator;
• a training coordinator;
• a payment provider;
• an approved business partner;
• service providers supporting our platform; or
• other parties where authorised or permitted by law.

7. Why We Collect and Use Personal Information

We may collect, hold and use personal information to:

• create and administer user accounts;
• register learners;
• provide access to courses;
• assign training;
• administer subscriptions;
• deliver learning content;
• record learner progress;
• administer assessments;
• generate certificates;
• verify certificates;
• manage organisational learning records;
• process payments;
• respond to enquiries;
• provide technical support;
• communicate service information;
• maintain security;
• prevent unauthorised use or fraud;
• improve our platform and services;
• conduct internal reporting and analytics;
• meet legal, regulatory and contractual obligations;
• manage complaints and disputes;
• protect our rights and the rights of users; and
• undertake other activities reasonably necessary to operate Prime Academy Group.

We seek to collect only information reasonably necessary for our functions and activities.

8. AI-Assisted Course Creation

Prime Academy Group provides AI-assisted functionality that may help users create, structure, edit, summarise or develop learning content.

Customer Content submitted for AI-assisted processing may be transmitted to technology providers that supply artificial intelligence, cloud computing or related infrastructure.

We seek to configure these services so that Customer Content is used only for the purpose of providing the requested functionality and subject to appropriate contractual, privacy and security safeguards.

Prime Academy Group does not itself sell Customer Content or personal information contained in Customer Content.

We do not intentionally use private Customer Content to train publicly available or general-purpose artificial intelligence models.

Where third-party artificial intelligence services are used, their handling of information is also subject to the relevant technical configuration and contractual arrangements implemented by Prime Academy Group.

Customers remain responsible for determining whether information they upload is appropriate for AI-assisted processing.

9. AI Outputs and Human Review

AI-assisted outputs may contain errors, omissions or inaccurate information.

AI-generated or AI-assisted training material should therefore be reviewed by an appropriately competent person before being approved, published or relied upon.

Prime Academy Group's platform is designed to enable organisations to review, edit, add, remove and customise AI-assisted content before publication.

The use of AI does not remove an organisation's responsibility to ensure that training content is appropriate, accurate, lawful and suitable for its intended purpose.

10. Automated Processing and Decisions

Certain functions may operate automatically, including:

• quiz scoring;
• assessment scoring where configured for automatic marking;
• progress tracking;
• course completion determination;
• certificate eligibility;
• course assignment;
• notifications; and
• account workflows.

These processes generally operate according to predefined rules and information provided through the platform.

Where an automated process could reasonably be expected to materially affect a learner's rights or interests, we may provide information about how that process operates and, where appropriate, a mechanism for requesting human review.

Users may contact us if they believe an automated outcome is incorrect.

11. Organisational Accounts and Learner Information

Where your access to Prime Academy Group is arranged by an employer or another organisation, that organisation may have authorised administrators who can access information relevant to the organisation's training program.

This may include:

• enrolment information;
• course assignments;
• course progress;
• completion status;
• assessment results;
• training history;
• certificate information; and
• compliance reports.

The organisation may independently have obligations regarding how it uses this information.

If you have questions about your employer's or organisation's use of your information, you should contact that organisation directly.

12. Disclosure to Service Providers

We may disclose information where reasonably necessary to service providers that assist us with:

• website hosting;
• cloud infrastructure;
• learning management systems;
• artificial intelligence processing;
• email delivery;
• authentication;
• cybersecurity;
• customer support;
• analytics;
• payment processing;
• accounting;
• data storage;
• backup;
• document processing;
• certificate generation;
• certificate verification; and
• professional services.

We seek to disclose only the information reasonably necessary for the relevant service.

13. Payments

Payments for paid courses and subscriptions may be processed through third-party payment providers.

Where a third-party payment gateway is used, payment card details may be provided directly to that provider rather than stored by Prime Academy Group.

The payment provider's privacy terms may also apply to information it processes.

We may retain transaction information including:

• amount paid;
• invoice number;
• transaction reference;
• payment status;
• date;
• customer identity; and
• other records required for accounting or business administration.

14. Overseas Processing and Data Hosting

Prime Academy Group uses cloud-based technology and may engage technology providers that operate infrastructure in Australia and overseas.

Accordingly, information may in some circumstances be stored, processed or accessed outside Australia.

Where practicable and required, we will provide information about material overseas locations relevant to the services being provided.

Where Australian data residency is contractually required, Prime Academy Group may offer an Australian-hosted or dedicated hosting arrangement under a separate enterprise agreement, subject to technical capability, availability and applicable fees.

Unless expressly agreed in writing, use of the standard Prime Academy Group service does not represent a guarantee that every component of all data processing will occur exclusively within Australia.

Where Australian privacy law applies to an overseas disclosure, Prime Academy Group will take reasonable steps required by applicable law in relation to the overseas recipient.

15. Customer Content and Confidentiality

Customer Content remains the customer's content.

We do not claim ownership of an organisation's underlying policies, procedures, manuals, confidential information or other proprietary material merely because it is uploaded to the platform.

We use Customer Content only as reasonably necessary to:

• provide the service;
• process requested AI functions;
• generate course content;
• store and deliver courses;
• provide support;
• maintain security;
• comply with legal requirements; or
• perform other activities authorised by the customer.

We do not sell private Customer Content to third parties.

Our personnel and service providers should only access Customer Content where access is reasonably necessary for authorised operational, technical, support, security or legal purposes.

16. Sensitive Information

Prime Academy Group does not generally require sensitive information to provide standard training services.

Customers and users should avoid uploading sensitive information unless it is genuinely necessary and appropriately authorised.

Sensitive information may include information concerning:

• health;
• disability;
• racial or ethnic origin;
• religious beliefs;
• sexual orientation;
• criminal history;
• political opinions; and
• other categories treated as sensitive information under applicable law.

Where sensitive information is intentionally collected by Prime Academy Group, we will seek to handle it in accordance with applicable legal requirements.

17. Disability, NDIS and Health-Related Training

Some Prime Academy Group courses relate to disability support, NDIS practice, health, infection prevention, mental health, behaviour support or other sensitive subject areas.

Participation in such a course does not ordinarily require a learner to provide personal health or disability information.

Learners should not include identifiable participant, client or patient information in:

• quizzes;
• assessments;
• discussion responses;
• support requests;
• chatbot conversations; or
• uploaded examples,

unless specifically requested through an approved and secure process and appropriately authorised.

18. Marketing Communications

We may send marketing communications where we have appropriate consent or another lawful basis to do so.

Marketing communications may include information about:

• new courses;
• free training;
• ready-made courses;
• subscription products;
• professional development;
• platform features;
• events;
• promotions; and
• related Prime Academy Group services.

Commercial electronic communications will provide a method for unsubscribing where required.

A person may withdraw marketing consent at any time.

Service communications necessary to administer an account, purchase, course, certificate, subscription, security issue or requested service are not necessarily marketing communications.

19. We Do Not Sell Personal Information

Prime Academy Group does not sell personal information to data brokers or unrelated third parties for their independent marketing purposes.

20. Security

We take reasonable technical and organisational measures designed to protect personal information and Customer Content against:

• loss;
• misuse;
• interference;
• unauthorised access;
• unauthorised alteration; and
• unauthorised disclosure.

Measures may include, where appropriate:

• access controls;
• authentication controls;
• encryption;
• secure cloud infrastructure;
• role-based permissions;
• monitoring;
• backup;
• logging;
• vulnerability management;
• restricted administrative access; and
• security procedures.

No internet-connected system can be guaranteed to be completely secure.

Users are responsible for maintaining the confidentiality and security of their own login credentials.

21. Data Breaches

Prime Academy Group maintains processes for identifying, assessing and responding to suspected data breaches.

Where applicable law requires notification of an eligible data breach, we will take steps required by law, which may include notifying affected individuals and the Office of the Australian Information Commissioner.

Users should promptly notify Prime Academy Group if they become aware of suspected unauthorised access to an account or information.

22. Retention of Information

We retain personal information only for as long as reasonably required for:

• providing services;
• maintaining accounts;
• training records;
• certificate verification;
• contractual obligations;
• accounting and taxation;
• security;
• legal compliance;
• dispute resolution; or
• other legitimate business purposes.

Different categories of information may therefore have different retention periods.

Course completion and certificate verification records may be retained after an account is closed where reasonably necessary to preserve the integrity and verifiability of issued credentials.

Customer Content may be deleted following account closure, contract termination or customer instruction, subject to:

• contractual requirements;
• backup cycles;
• technical limitations;
• applicable retention settings;
• legal obligations; and
• legitimate security requirements.

Temporary copies generated by cloud, backup or AI-processing systems may remain for limited periods before being automatically removed according to applicable system configurations.

23. Deletion and De-Identification

Where personal information is no longer required and there is no legal or legitimate reason to retain it, we may take reasonable steps to destroy or de-identify it.

A request to delete information may be subject to information that Prime Academy Group is required or reasonably entitled to retain, including transaction records and certificate verification records.

24. Access to Personal Information

You may request access to personal information we hold about you.

Requests should be sent to:

Privacy Officer
Prime Academy Group
Email: info@primeacg.com

We may need to verify your identity before providing access.

There may be circumstances where access may lawfully be refused or limited. Where appropriate, we will explain the reason.

25. Correction of Personal Information

If you believe information held by Prime Academy Group is inaccurate, incomplete, out of date, irrelevant or misleading, you may request correction.

Please contact:

info@primeacg.com

We may request sufficient information to verify the requested correction.

26. Anonymous or Pseudonymous Interaction

Where practical, individuals may make general enquiries without identifying themselves or may use a pseudonym.

Identification will generally be required where necessary to:

• establish an account;
• enrol in training;
• process payment;
• track course completion;
• complete assessments;
• issue or verify a certificate;
• provide organisational reporting; or
• comply with legal or contractual requirements.

27. Third-Party Links

Our websites or courses may contain links to external websites or services.

Prime Academy Group is not responsible for the privacy practices of unrelated third parties.

Users should review the privacy policies of external services before providing personal information.

28. Complaints

If you believe Prime Academy Group has mishandled your personal information, please contact our Privacy Officer.

Email: info@primeacg.com
Telephone: 1800 447 677

Please provide sufficient information for us to understand and investigate your concern.

We will aim to:

• acknowledge the complaint within a reasonable period;
• investigate the issue;
• communicate with relevant personnel or service providers where necessary; and
• provide a response within a reasonable timeframe.

Where the Privacy Act applies and you are not satisfied with our response, you may have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC).

29. Changes to this Privacy Policy

We may update this Privacy Policy where:

• our services change;
• technology changes;
• our data practices change;
• legal requirements change;
• new functionality is introduced; or
• additional service providers are engaged.

The latest version will be published on our website with the date of the most recent update.

Where a change materially affects how existing personal information is handled, we will take reasonable steps to provide appropriate notice where required.

30. Contact Prime Academy Group

For privacy enquiries, access requests, correction requests or complaints:

Prime Academy Group
A trading name of ISO Prime Pty Ltd

Email: info@primeacg.com
Telephone: 1800 447 677
Website: primeacg.com
Website: primeacg.com.au

Head Office
6 Peter Street
Doncaster East VIC 3109
Australia

Privacy enquiries:
Please use the subject line “Privacy Enquiry” when contacting us by email.