AADHAAR HOLDINGS PTY. LTD. (Australian Business Number 12 604 794 452) trading as First Source World with address of Unit 27, 2 O'Connell St, Parramatta, NSW, Australia, 2150 (herein after referred to as “First Source World”, “we”, “us” or “our”) are committed to protecting the privacy or the User (herein after referred to as “you” or “your”) and complying with applicable data protection and privacy laws.
This privacy policy (“Privacy Policy”) together with our Terms of Service, Data Processing Agreement, Subscription Agreement and any other document referred to in this Privacy Policy describes our policies and procedures on the collection, use, disclosure and any other treatment of your Personal Data when you register for or use the FSW Services. We use your Personal Data to provide you with the FSW Services and to improve the FSW Services. By using the FSW Services, you accept the terms of the Privacy Policy and agree to the collection and use of Personal Data in accordance with this Privacy Policy. In the event of a conflict with the terms of this Privacy Policy and the Terms of Service, the Terms of Service will prevail.
1. Interpretation and Definitions
The words of which the initial letter is capitalized have the meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
1.1 Definitions
For the purposes of this privacy policy:
- “Academic Information” includes academic transcripts, academic qualification certificates, English language certificates, and any other documentation that evidences the completion of an academic or language qualification;
- “Account” means a unique account created for you to access the FSW Services or part of the FSW Services;
- “Affiliate” means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority;
- “Cookies” means small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses;
- “Data Processing Agreement” means the First Source World Data Processing Agreement which can be accessed at https://firstsourceworld.com/data;
- “Device” means any device that can access the FSW Services such as a computer, cell phone or digital tablet;
- “First Source World” means AADHAAR HOLDINGS PTY. LTD. (Australian Business Number 12 604 794 452) trading as First Source World with address of Unit 27, 2 O'Connell St, Parramatta, NSW, Australia, 2150 (also referred to as “we”, “us” or “our” throughout this Privacy Policy);
- FSW Services means any or all of the products developed by First Source World including the First Source World CRM, which includes the Referral Portal and Client Portal, First Source World Customer App and any and all other products or services which are described at https://firstsourceworld.com;
- “EEA” means the European Economic Area;
- “Information” includes Personal Data, Usage Data and any other forms of identifying or non-identifying data relating to you;
- “EU” means the European Union;
- “Personal Data” means any information relating to an identified or identifiable individual (i.e. a natural person);
- “Privacy Policy” means this privacy policy;
- “Service Provider” means any natural or legal person who processes the data on behalf of First Source World. It refers to third-party companies or individuals employed by First Source World to facilitate the FSW Services or to assist First Source World in analysing how the FSW Services is used;
- “Subscription Agreement” means the First Source World Subscription Agreement relevant to the subscription of the First Source World CRM; “Terms of Service” means the First Source World Terms of Service which can be accessed at https://firstsourceworld.com/terms;
- “Usage Data” refers to data collected automatically, either generated by the use of the FSW Services or from the FSW Services infrastructure itself (for example, the duration of a page visit);
- “User” means the individual accessing or using the FSW Services, or the company, or other legal entity on behalf of which such individual is accessing or using the FSW Services, as applicable (also referred to as “you” or “your” throughout this Privacy Policy);
- Website means First Source World's website which is accessible from https://firstsourceworld.com.
2. Collecting and Using Your Personal Data
By registering for or using the FSW Services we may collect and process the following information about you:
2.1 Personal Data
By registering for or using the FSW Services we may ask you to provide us with certain Personal Data that can be used to contact or identify you. Personal Data we may collect may include but is not limited to your:
- Email address
- First name and last name
- Phone number
- Usage Data
- Academic Information
- Passport
2.2 Usage Data
Usage Data may be collected automatically when using the FSW Services. Usage Data that is collected may include:
- Technical information that your browser sends whenever you visit a website or your mobile app sends when you are using it. This log data may include your Internet Protocol (IP) address, the address of the web page you visited before using the FSW Services, your browser type and settings, the date and time of your use of the FSW Services, information about your browser configuration and plugins, language preferences and Cookies.
- Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page and any phone number used to call out customer service number.
- Publicly accessible data about you from social media websites that you visit when using the FSW Services.
- Non-personally identifiable information (e.g. gender and location) to assist in providing the FSW Services to you. Non-personally identifiable information by itself cannot be used to identify or contact you. However, this information may be combined with other identifiers in a way that enables you to be identified.
2.3 Information Collected from Other Sources
We may receive Information about you if you use any of the other websites that we operate or the other services that we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected via the FSW Services.
We may receive Information about you from third parties (including but not limited to education agents, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information and credit reference agencies). All Information about you which is received from third parties will be treated in accordance with this Privacy Policy.
2.4 Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on the FSW Services and store certain Information. Tracking technologies used includes beacons, tags and scripts to collect and track information and to improve and analyse the FSW Services. The tracking technologies we may use include:
- Cookies or Browser Cookies: A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of the FSW Services. Unless you have adjusted your browser setting so that it will refuse Cookies, the FSW Services may use Cookies.
- Web Beacons: Certain sections of the FSW Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixels tags, and single-pixel gifs) that permit us to, for example, count users who have visited those pages or opened an email and for other related website statistics, such as recording the popularity of a certain section and verifying system and server integrity.
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your Device when you go offline, while Session Cookies are deleted as soon as you close your web browser. We use both Session and Persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies: Session Cookies administered by us. These Cookies are essential to provide you with the FSW Services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the FSW Services that you have asked for cannot be provided. We only use these Cookies to provide you with those FSW Services.
- Cookies Policy / Notice Acceptance Cookies: Persistent Cookies administered by us. These Cookies identify if users have accepted the use of cookies on the website.
- Functionality Cookies: Persistent Cookies administered by us. These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the website.
3. Use of Your Information
We may use your Information for the following purposes:
- To provide and maintain the FSW Services, including to monitor the usage of the FSW Services.
- To manage your Account: to manage your registration as a user of the FSW Services and any billing and payments that occurs as a result of your usage of the FSW Services. The Information you provide can give you access to different functionalities of the FSW Services that are available to you as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the FSW Services.
- To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates when necessary or reasonable for their implementation.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
- To notify you of any changes to the FSW Services, including but not limited to any changes in the functionality of the FSW Services, the Terms of Service, the Data Processing Agreement, this Privacy Policy and the price of the FSW Services.
- To manage your requests: To attend and manage your requests to us.
- To improve the FSW Services.
- For business transfers: We may use your information to evaluate or conduct a merger, divesture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Information held by us about the FSW Services users is among the assets transferred.
- For other purposes: We may use your Information for other purposes, such as data analytics, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the FSW Services, products, services, marketing and your experience.
4. Retention of Your Information
We will retain your Information only for as long as is necessary for the purposes set out in this Privacy Policy, for the delivery of the FSW Services or for as long as your Account remains open (whichever is latest).
We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, to comply with any applicable laws), resolve disputes and enforce our legal agreements and policies.
We will retain Usage Data for internal analysis purposes including but not limited to strengthen the security of the FSW Services or to improve the functionality of the FSW Services.
5. Transfer of Your Information
Your Information, including Personal Data, is processed at First Source World's operating offices and in any other places where the parties in the processing are located. This means that this Information may be transferred to, and maintained on, Devices and computer servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from your jurisdiction. Your consent to this Privacy Policy followed by your submission of such Information represents your agreement to this transfer of Information. First Source World will take all steps reasonably necessary to ensure that your Information is treated securely and in accordance with this Privacy Policy and no transfer of your personal Information will take place to an organisation or a country unless there are adequate controls in place which include the security of your Information and other personal information.
6. Delete Your Personal Information
You have the right to delete or request that we assist in deleting the Information that we have collected about you. The FSW Services may give you the ability to delete certain Information about you from within the FSW Services. You may update, amend or delete your Information at any time by signing into your Account, if you have one, and visiting the account setting section that allows you to manage your Information. You may also contact us to request access to, correct, or delete any Information that you have provided to us. Please note, however, that we may need to retain, and in these circumstances will retain, certain information when we have a legal obligation or lawful basis to do so.
7. Disclosure of Your Information
We may share your Information with any of our Affiliates.
7.1 Information We Share with Third Parties
We may share your Information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you and for the purpose of providing part of the FSW Services to you. Such third parties supply the hardware infrastructure, storage and associated services necessary for us to provide the FSW Services. All information submitted to third parties will be encrypted using SSL technology. By using our Website and/or the FSW Services, you consent to our third party service partners having access to your Information.
- In situations where you, your employer or your education agent (as the case may be) have entered into the First Source World Student Referral Agreement, your Personal Data may be shared with certain education agents in accordance with the First Source World Student Referral Agreement.
- Analytics and search engine providers that assist us in the improvement and optimization of the FSW Services.
7.2 Information That We Disclose to Third Parties
To prevent unauthorised access to your Information, we follow strict guidelines in the storage and disclosure of Information which you have given us. We comply with the laws of the countries from which we operate. We may disclose your Information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your Information to the prospective seller or buyer of such business or assets.
- If First Source World or substantially all of its assets are acquired by a third party, in which case Information held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and/ or any other agreements; or to protect the rights, property, or safety of First Source World or our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
In complying with court orders and similar legal processes, we strive for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.
8. Security of Your Information and Third-Party Links
The security of your Information is important to us but you should be aware that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially and legally acceptable means to protect your Information, we cannot guarantee that it is absolutely secure.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the FSW Services, you are responsible for keeping this password confidential. We ask you not to share any password with anyone.
The FSW Services may contain links to and from third party websites of our partners, networks, advisers and Affiliates. If you follow a link to any third-party website from the FSW Services, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for the privacy practices or content of these websites.
9. Children's Privacy
The FSW Services may not be used by persons under the age of 16 years old. You may not provide, upload or otherwise store any Personal Data relating to persons under the age of 16 years old. We do not knowingly collect Personal Data from anyone under the age of 16 years old. If we learn or have reason to suspect that you are a user who is under the age of 16 years old, we will close your Account. If you provide, upload or otherwise store any Personal Data relating to persons under the age of 16 years old, we will close your Account. Please see our Terms of Service regarding Account termination. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us.
10. Applicable Data Protection Law
For the purposes of the General Data Protection Regulation (EU) 2016/679. The data controller is First Source World.
11. Where We Store Your Information for EU Customers
The Information that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for our suppliers or Affiliates. Such staff may be engaged in, among other things, the provision of support services. By submitting your Personal Data, you agree to this transfer, storing or processing outside of the EEA. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.
We always ensure that your Information is only transferred in full accordance with Australian data protection laws and all applicable EU protection laws. In particular, this means that your information will only be transferred to a country that provides an adequate level of protections (for example, because the European Commission has determined that a country provides an adequate level of protection) or the recipient is bound by standard contractual clause(s) according to conditions provided by the European Commission (“EU Model Clauses”). You are responsible for checking the privacy policy of any third-party websites that we link to.
The FSW Services are accessible via the internet and may be potentially accessed by any user around the world. Other users may access the FSW Services from outside the EEA. This means that where you chose to upload your Personal Data to the FSW Services, it could be accessed from anywhere around the world and therefore a transfer of your data outside of the EEA may be deemed to have occurred. You consent to such transfer of your Personal Data and Information for and by way of this purpose.
12. Changes to This Privacy Policy
We reserve the right to change this Privacy Policy at any time and the amended Privacy Policy will be posted at https://firstsourceworld.com/privacy and notified to you by email, where appropriate. Please check back frequently to see any updates or changes to our Privacy Policy. This Privacy Policy was last updated on 30th of June, 2024 and replaces any other Privacy Policy previously applicable from this date.
13. Contact Us
Questions, comments and requests regarding this Privacy Policy are welcomed and should be forwarded by email to: contact@firstsourceworld.com.
