1. About this Privacy Policy
1.1 This Privacy Policy explains how FIFTH DOMAIN Pty Ltd (ABN 92 606 251 585) ("FIFTH DOMAIN", "we", "us" or "our") collects, holds, uses, discloses and otherwise handles personal information in connection with our website, the 5D.PRO platform, hosted environments, assessments, competitions, learning labs, content and related services (together, the Platform or Services).
1.2 We are committed to protecting privacy and handling personal information in an open and transparent way.
1.3 We handle personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), and any other applicable Australian privacy, data protection and related laws.
1.4 This Privacy Policy should be read together with our Terms and Conditions of Use and any other notices we provide to you when collecting your personal information.
1.5 We may also use Artifical Intelligence (AI) enabled or automated tools as part of the Platform or Services. Further information about our approach to responsible AI use is available in our Customer Artificial Intelligence (AI) Trust and Safety Policy.
2. Who this Privacy Policy applies to
2.1 This Privacy Policy applies to personal information we collect about:
visitors to our website;
individual users of the Platform;
users whose access is provided through an employer, school, training provider, recruiter, event organiser or other organisation;
participants in competitions, assessments, labs, training programs and events;
customers and prospective customers;
job applicants and candidates where relevant to our Services; and
other individuals who interact with us.
2.2 In this Privacy Policy, personal information has the meaning given in the Privacy Act 1988 (Cth), and generally means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
3. What personal information we collect
3.1 The kinds of personal information we collect depend on how you interact with us and the Services you use.
3.2 We may collect the following categories of personal information when you interact with our website or Platform:
Identity and profile information, such as:
name
username or gaming alias
photograph or profile image
age range
Contact information, such as:
email address
phone number
residential, billing or postal address
Organisation, education and professional information, such as:
employer or school name
job title or role
training history
educational background
years of experience
cohort, team or organisational affiliation
Transaction and billing information, such as:
billing contact details
billing address
subscription or purchase records
payment status
Assessment, training and performance information, such as:
course progress
challenge and lab activity
assessment responses and results
competition participation and scores
cyber capability indicators
engagement metrics
achievement history
reports, insights and benchmarking outputs generated through the Platform
Technical and usage information, such as:
IP address
device type
operating system
browser type
cookies and similar technologies
log data
dates and times of access
pages viewed
clickstream and interaction data
diagnostic and telemetry information
Support and communications information, such as:
enquiries
complaints
feedback
support tickets
correspondence with us
Audio, visual and uploaded content, such as:
images
audio recordings
video recordings
documents
notes
signatures
other content uploaded through the Platform
3.3 We generally do not seek to collect sensitive information unless it is reasonably necessary for our functions or activities, permitted by law, or you have provided it to us in connection with the Services. If we do collect sensitive information, we will handle it in accordance with applicable law.
3.4 We do not require users to provide gender information unless it is reasonably necessary for a specific function, event or lawful purpose. If such information is collected, we will explain why.
4. How we collect personal information
4.1 We may collect personal information directly from you when you:
submit a ‘Contact Us’ form via our website;
create an account;
use the Platform or Services;
participate in an assessment, competition, lab or training activity;
make a purchase or payment;
contact us or submit a support request;
sign up to receive updates or marketing communications;
upload content or otherwise interact with the Platform.
4.2 We may also collect personal information from third parties where lawful and reasonably necessary, including from:
your employer;
a school, training provider or educational institution;
a recruiter or event organiser;
payment providers;
identity verification providers;
analytics or technology providers;
publicly available sources; or
other persons authorised by you or by law.
4.3 If you provide personal information about another person to us, you must take reasonable steps to ensure you are authorised to do so and that the person is aware of this Privacy Policy.
5. Cookies, analytics and similar technologies
5.1 We may use cookies, web beacons, pixels, log files and similar technologies to collect technical and usage information.
5.2 We use these technologies to:
operate and secure the Platform;
remember preferences and settings;
understand how users interact with the Platform;
improve performance and functionality;
generate aggregated analytics and insights;
measure the effectiveness of communications and campaigns.
5.3 You can manage cookies through your browser settings. If you disable cookies, some parts of the Platform may not function properly.
6. Device permissions and optional collection
6.1 Depending on the Services you use, we may request access to device features such as your camera, microphone or location.
6.2 We will only access those features where reasonably required for a Platform function and, where applicable, after you grant permission through your device or browser settings.
6.3 You can disable these permissions through your device settings, but some features may not work properly if you do so.
6.4 We do not collect background location data unless this is clearly disclosed to you in advance and is reasonably necessary for a specific service, safety function or agreed operational purpose.
7. Why we collect, use and disclose personal information
7.1 We may collect, hold, use and disclose personal information for the following purposes:
to provide, operate, administer, support and improve the Platform and Services;
to create and manage accounts;
to verify identity where reasonably required;
to run competitions, assessments, training programs, labs and events;
to generate reports, results, analytics, benchmarking and insights;
to communicate with you about the Platform, your account, support issues and service updates;
to process payments and manage billing;
to respond to enquiries, complaints and requests;
to protect the security and integrity of the Platform;
to investigate suspected misuse, fraud or unlawful activity;
to comply with legal and regulatory obligations;
to enforce our legal rights and agreements;
to conduct internal business operations, planning, research and service development;
to send marketing communications where permitted by law.
7.2 Where your access is provided through an employer, school, training provider, recruiter, event organiser or other organisation, we may disclose information about your participation, activity, progress, performance, results or submissions to that organisation where this is part of the Services being provided to it.
7.3 We may use AI-enabled or automated tools as part of the Platform or Services, including for functions such as summarisation, classification, analysis, recommendations, search, user assistance, reporting, scoring, ranking or insight generation, depending on the Services being used.
7.4 We may generate derived, aggregated, de-identified, anonymised or transformed information from personal information or Platform activity to support analytics, benchmarking, service improvement, security, research and AI-enabled functionality, provided we take reasonable steps to ensure that individuals are not identified where the information is used or disclosed in de-identified or anonymised form.
7.5 We do not sell personal information as a standalone data product.
8. When we disclose personal information
8.1 We may disclose personal information to:
related entities and corporate service providers;
customers that provide or manage your access to the Platform;
schools, training providers, employers, recruiters and event organisers connected with your use of the Services;
payment processors and billing providers;
cloud hosting, infrastructure, communications, identity verification, support, analytics, security and AI-enabled service providers;
professional advisers, auditors and insurers;
regulators, law enforcement bodies, government agencies, courts or tribunals where required or authorised by law;
other parties where you have expressly authorised the disclosure.
8.2 We take reasonable steps to ensure that third-party service providers who handle personal information on our behalf are subject to appropriate privacy and security obligations.
8.3 We take reasonable steps to ensure that third-party service providers who handle personal information on our behalf, including providers supporting AI-enabled functionality, are subject to appropriate privacy, security and contractual controls.
8.4 As a general rule, personal information and other customer data processed through the Platform are used to provide Services and functionality to the relevant customer and are not used to train shared third-party AI models or provided for third-party AI development.
9. Overseas disclosures
9.1 We may disclose personal information to third-party service providers located outside Australia, including providers that host or support our Platform, communications, analytics, security, customer support or other operational systems.
9.2 Where we disclose personal information overseas, we will take reasonable steps in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to that information, unless an exception under the Privacy Act applies.
9.3 Further information about overseas disclosures may be available on request.
10. Direct marketing
10.1 We may use your personal information to send you information about our Services, updates, events, products or opportunities that we think may be of interest to you, where permitted by law.
10.2 Where required, we will obtain your consent before sending you direct marketing communications.
10.3 You can opt out of receiving marketing communications at any time by using the unsubscribe function in the communication or contacting us using the details below.
11. Automated processing, profiling and Ai-enabled outputs
11.1 Because the Platform includes assessments, competitions, training and workforce capability tools, we may use automated processing to generate scores, rankings, insights, recommendations, skill profiles, benchmarking or similar outputs.
11.2 These outputs may be shared with the relevant customer, employer, school, recruiter, event organiser or other organisation that provides or manages your access to the Services, where that is part of the relevant service.
11.3 Depending on the use case, AI-enabled outputs may be subject to human review, verification, testing or monitoring, and may not be the sole basis for action where additional judgement or review is appropriate.
11.4 You may contact us if you would like more information about how these outputs are generated or if you have concerns about the accuracy of personal information used in producing them.
12. Security
12.1 We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.
12.2 Those steps may include technical, administrative and physical safeguards such as access controls, authentication measures, encryption, monitoring, staff training, secure development practices, data minimisation and retention controls.
12.3 While we take reasonable steps to protect personal information, no method of transmission over the internet or method of electronic storage is completely secure.
13. Data breaches
13.1 If we become aware of a suspected or actual data breach involving personal information, we will assess and respond to it in accordance with the Privacy Act 1988 (Cth), including the Notifiable Data Breaches scheme where applicable.
13.2 Where required by law, we will notify affected individuals and the Office of the Australian Information Commissioner.
14. Retention and destruction
14.1 We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, and as required or permitted by law.
14.2 When personal information is no longer required, we will take reasonable steps to destroy it or de-identify it, unless we are required or permitted by law to retain it.
14.3 Different retention periods may apply depending on the type of information, the Services used, whether your access was provided by a Customer, and our legal, regulatory, operational and security obligations.
14.4 Information contained in backups, logs, audit trails or archived records may be retained for longer where reasonably necessary for legal, security or operational purposes.
15. Access and correction
15.1 You may request access to the personal information we hold about you.
15.2 You may also request that we correct personal information we hold about you if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.
15.3 We will respond to requests for access or correction within a reasonable period and in accordance with applicable law.
15.4 In some circumstances, the Privacy Act permits us to refuse access or correction. If we do so, we will provide reasons where required by law.
16. Anonymity and pseudonymity
16.1 Where lawful and practicable, you may have the option of interacting with us anonymously or using a pseudonym.
16.2 However, in many cases we will need your real identity in order to provide the Services, verify your account, administer assessments or competitions, provide reports, manage billing, or comply with legal obligations.
17. Children and young people
17.1 The Platform is not intended for children under 12.
17.2 If you are under 18, you may only use the Platform where access has been authorised by a parent, legal guardian, school, training provider, employer or other authorised organisation, and any required permissions, notices and consents have been obtained.
17.3 We do not knowingly collect personal information from children in circumstances where doing so would be unlawful.
17.4 If you believe that a child has provided us with personal information inappropriately or without required authorisation, please contact us and we will investigate.
17.5 We take additional care where Services are likely to be accessed by children or young people.
18. Third-party links and services
18.1 The Platform may contain links to third-party websites, applications or services.
18.2 We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing personal information to them.
19. Changes to this Privacy Policy
19.1 We may update this Privacy Policy from time to time.
19.2 If we make a material change, we will take reasonable steps to notify affected individuals, for example by posting the updated policy on the Platform, sending an email, or providing another prominent notice.
19.3 The updated version will apply from the date stated at the top of this Privacy Policy.
20. Complaints and contact details
20.1 If you have a question, request or complaint about how we handle personal information, please contact us using the details below.
20.2 We will consider your complaint and respond within a reasonable period.
20.3 If you are not satisfied with our response, you may make a complaint to the Office of the Australian Information Commissioner.
20.4 To make an access, correction or privacy complaint request, please contact us using the details below.
FIFTH DOMAIN Pty Ltd
UNSW Launch on Northbourne
Ground Floor
216 Northbourne Avenue
Braddon ACT 2612 Australia
Email: support@fifthdomain.pro