Privacy Policy

Last revised 11 Aug 2025

Kineo, a Mindtools business, is committed to data security and the fair and transparent processing of personal data. This privacy notice sets out how we will treat the personal data which you provide to us in compliance with applicable data protection law, including the General Data Protection Regulation (EU) 2016/679 (EU GDPR), The UK GDPR and Data Protection Act 2018 (DPA). You can find out more about the Mindtools businesses here About us | Mindtools (mindtools.com)

Please read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data, how to contact us and supervisory authorities in the event that you would like to report a concern about the way in which we process your data.

Who are we?

Kineo Mind Tools Pty Ltd ABN 94 686 441 190, trading as Kineo, and all other subsidiaries, business units and entities associated with Mindtools businesses (“we, our, us”) are committed to data security and the fair and transparent processing of Personal Information or Personal Data (herein Personal Information) when providing services to corporate and government Clients across Australia, New Zealand, the United Kingdom, the United States of America and Mexico and Argentina.

For the purposes of applicable data protection law, Kineo, a Mindtools business, is the ‘controller’ of the personal data you provide to us or one of our associated companies (together the Mindtools businesses). We work closely with our associated companies including processing of personal data, see our other companies’ privacy notices for more information.

We are committed to protecting the privacy of your Personal Information. This Privacy Notice, together with our website terms of use and any other documents referred to in them, sets out the basis on which we process personal data via our website, how we collect, use, disclose and otherwise handle Personal Information and how we will treat the personal data which you provide to us in compliance with applicable data protection laws. It also tells you how you can ask to access and correct the Personal Information we hold about you or complain about a suspected privacy breach.

We are required to comply with all privacy laws applicable in the jurisdiction in which you reside (including, but not limited to, the Australian Privacy Principles (APPs), the Privacy Act 1988 (Cth) in Australia, the Privacy Act 1993 in New Zealand, General Data Protection Regulation (EU GDPR) 2016/679 (EU GDPR), the UK GDPR, Data Protection Act 2018 (in UK) and all applicable US legislation).

We are also required to comply with more specific privacy legislation in some circumstances, such as applicable State and Territory health privacy legislation in Australia, the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth). As well as the Privacy and Electronic communication Regulations (PECR) in the UK.

For the purposes of applicable data protection law, ‘we, us, our’ refers to the ‘processor’ of the Personal Information you provide to any entity within the Mindtools businesses.

Mindtools owns and operates www.mindtools.com (Mindtools Website).

Kineo owns and operates www.kineo.com (.com/en-au, .com/en-us, .com/es). Kineo Mind Tools owns and operates kineocourses.com.au, trial.kineocourses.com (.com.au / .co.nz), productupdates.kineoportal.com, knowledgebase.kineoportal.com (Kineo Website). This Notice, together with our Website terms of use and any other documents referred to in them, sets out the basis on which Mindtools and Kineo processes Personal Information via our Mindtools Website or our Kineo Website (together, the Websites).

What personal data do we collect?

We may collect and process the following personal data.

Information you provide to us:

If you:

complete a form on one of our Websites; or
answer a question on one of our Websites; or
complete a survey; or
correspond with us by phone, email, or in writing; or
report a problem; or
sign up to receive communications; or
sign up to receive our newsletter; or
create an account with us; and
enter into a contract with us to receive products and/or services.

We may collect your name, gender, email address, postal address, telephone number, job role, drivers licence and/or passport details, student ID number username, password, security question and answer, work site details such as name, and address. If we need to communicate with you, we may collect your email, residential and postal addresses, and telephone numbers (if a work site we may collect your work site phone number and your worksite contact email). If you apply to enrol in a training course or otherwise access our services, we may collect details of your employment and employer (or, if you are a contractor, your head contractor), training and compliance history, qualifications, banking and payment details.

Information we collect about you

If you visit any of our Websites, we may automatically collect the following information:

technical information, including the internet protocol (IP) address used to connect your computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
information about your visit to our website such as the products and/or services you searched for and view, 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.

How we collect information and Personal Information about you

We will collect information about you, and when we collect Personal Information about you it will be by lawful and fair means, as follows:

directly from you in person, over the phone, through written communications (either on paper or electronic) or by you completing forms or answering questions on our Websites; or
from third parties if it is unreasonable and impracticable for us to collect it from you, including your employer, (or, if you are a contractor, your head contractor), direct marketing database providers, government agencies, our related companies and your authorised representatives; and
from our own records of your use of our services which we have collected from you.

Information we receive from other sources

We may also receive personal data about you if you use any of the other websites which we, or another company within the Mindtools business, or the other services and/or products which we, or another company within the Mindtools business, provide. You can find out more about the Mindtools business here About us | Mindtools (mindtools.com) or Kineo business here About us | Kineo (Kineo.com). If it is unreasonable and impracticable for us to collect any Personal Information from you and you are a tutor, apprentice, learner, contractor or supplier we may also receive Personal Information or other information about you from your centre, training provider, or employer when they register to receive products and/or services from us, or a supplier or contractor when you register to receive products and/or services from us.

We use this information to help us improve our services. We may aggregate this information for our own statistical purposes. Provided that it remains anonymous, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.

If you are a learner, we may also receive information about you from your training provider or employer when they register to receive products and/or services from us.

Information about other people

If you provide information to us about any person other than yourself, such as your colleagues, your employees, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

Sensitive personal information

In certain limited cases, we may collect certain sensitive personal data from you (that is, information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences, or genetic or biometric data).

How do we use your personal data?

When we ask you to supply us with personal data, we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.

Contract performance

We may use your personal data to fulfil a contract, or take steps linked to a contract:

to provide the products and/or services to you
to communicate with you in relation to the provision of the contracted products and services
to provide you with administrative support such as account creation, security and responding to issues
to provide you with industry information, surveys, information about our awards and events, offers and promotions, related to the products and/or services

Legitimate interests

Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests are:

providing you with newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by a Mindtools business which may be of interest to you
communicating with you in relation to any issues, complaints, or disputes
improving the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our website
performing analytics on sales/marketing data, determining the effectiveness of promotional campaigns
developing, improving, and delivering marketing and advertising for products and services offered by a Mindtools business.

The main purposes for which we collect, hold, use and disclose Personal Information are:

to identify you and verify your identity; or
to communicate with you about our services; or
to provide our services to you, including but not limited to, facilitating your enrolment in online training, facilitating your access to online training materials, verifying and validating your compliance history, facilitating your communications with others via our Websites and for obtaining payment for our services; or
for purposes required or authorised by or under law; or
to help us improve our services; and
for any other purposes that you have consented to.

Where required by law, we may also process your Personal Information including but not limited to responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

You have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading ‘Your rights’.

Consent

We may process sensitive personal data where you have provided explicit consent to us, or a third party who has provided sensitive personal data to us.

We may also process your personal data if required by law, including but not limited to responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

Who do we share your personal data with?

In some circumstances we share personal data within the Mindtools business, including Mindtools companies registered in the UK and outside of the UK (including Kineo companies and branches internationally), to maintain and improve current and future services, customer engagement, and sales opportunities across our business.

Any shared access of personal data is subject to restrictions both legally and contractually. We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.

We may also share your personal data with trusted third parties including:

legal and other professional advisers, consultants, and professional experts;
service providers contracted to us in connection with provision of the products and services such as providers of IT services and customer relationship management services; and
analytics and search engine providers that assist us in the improvement and optimisation of our website.

We will ensure there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.

We may disclose your Personal Information to any of the organisations that we deal with in the ordinary administration of our business for the purposes set out above, including:

your employer, (or, if you are a contractor, your head contractor); or
financial institutions; and
our service delivery partners, including:
information technology service providers (including cloud services providers); or
mailing houses, postal, freight and courier service providers; or
printers and distributors of client communications; and
external business advisers (such as recruitment advisers, auditors and lawyers).

In each case, we may disclose Personal Information or data to the service provider and the service provider may in turn provide us with Personal Information collected from you.

We may de-identify and aggregate the Personal Information of you and others for our own statistical purposes. Provided that it remains permanently de-identified, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.

If you apply for a job with us, we may discuss your application with your nominated referees.

If you have an online account via any one of our Websites, and you need to change your privacy settings of your account, you will need to contact us, some of the Personal Information in your user profile may be disclosed to other users.

If you post comments or otherwise communicate publicly with other users via any of our Websites, any information about yourself that you include in the communication may be stored on that Website and accessed by other users. For this reason, we encourage you to use discretion when deciding whether to post any information that can be used to identify you.

Australia / New Zealand / United States / South Africa / Mexico / Argentina
Where a third-party recipient is located outside Australia, New Zealand, the United States of America, Mexico, Argentina and/or South Africa, we will ensure that the transfer of Personal Information will be protected by appropriate safeguards, to comply with the requirements of applicable privacy laws in the relevant jurisdiction and any provisions of the Privacy Act and the Australian Privacy Principles, the requirements of the Privacy Act 1993 in New Zealand and any applicable privacy laws in the United States and South Africa that apply to cross border disclosures. We will share personal data with law enforcement or other authorities if required by applicable law.

How long will we keep your personal data?

Where there is a contract between us, we will retain your personal data for the duration of the contract, and for a period following its termination or expiry, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

Wider personal information processed outside of customer relationships follows internal retention and disposal policies.

Marketing

Where you receive marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in any email from us.

We may send you email marketing communications about Kineo and Mindtools businesses products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with applicable law including any consent requirements that maybe imposed by applicable law. When we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

When you visit our Sites or online services, both we and certain third parties collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interested-based advertising”). These third parties may place or recognise a unique cookie or other technology on your browser (including the use of pixel tags). Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of interest-based advertising.

YWhen you visit our Sites or online services, both we and certain third parties collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interested-based advertising”). These third parties may place or recognise a unique cookie or other technology on your browser (including the use of pixel tags). Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of interest-based advertising.

You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users based on a range of actors including demographic data, users’ inferred interests and browsing context (for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.

We work with Google Ads, Google Display Network, LinkedIn, Twitter and other advertising networks.

You can opt out of receiving these communications at any time, in the following ways:

if you have an online account via one of our Websites, you can update your communications preferences by logging in to your account and following the instructions on the relevant Website; or
contact us and tell us; and
where you receive marketing communications from us, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us.

To learn how to opt out of behavioural advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initiative and Digital Advertising Alliance. You may download the “AppChoices” app to opt out in mobile apps. At present there is no industry standard for recognising Do Not Track browser signals, so we do not respond to them.

Where do we store your personal data and how is it protected?

Personal information received within the UK & EEA is stored with an industry recognised data centre based in the EU.

Personal information received from customers within the USA is stored within an industry recognised data centre based in the USA.

Personal information received from Australia and New Zealand (including, in some circumstances, if you reside in the UK or the European Union) is stored in secure data centres in Australia although we may use third parties to store your data outside of Australia, whenever this happens we take reasonable steps to protect your personal data/information from loss or destruction.  We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data/information security breach where we are legally required to do so.

For any international transfers we will ensure that approved safeguards are in place to ensure that we comply with applicable data protection laws, including international data transfer agreements in the UK, and the use of standard data protection clauses adopted or approved by the European Commission when applicable.

Your rights

Under applicable data protection law, you have various rights with respect to our use of your personal data:

Right to access
You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond within 1 month of request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information. Or if your request is manifestly unfounded or excessive.

Right to rectification
We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up to date.

Right to erasure
You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to object
In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.

Right to restrict processing
In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have queried the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below.

Right to data portability
In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to Personal Information of others without their consent.

Right not to be subject to solely automated decisions
In certain circumstances you have the right not be subject to solely automated decisions that may have a legal or similar effect, this includes profiling. This right may arise when solely automated processing does not have meaningful human involvement, including application of Artificial Intelligence and other forms of automated processing. If you would like to know more about how we ensure such rights for data subjects please contact us using the contact details provided below.

If you would like to exercise any of the above rights and request that your Personal Information is ported to you, please contact us using the contact details provided below.

Please note that applicable data protection law sets out exceptions to these rights. If we are unable to comply with your request due to an exception, we will explain this to you in our response.

To the extent that we are processing your Personal Information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section below.

Third Party Service Providers

As mentioned above, we will share your Personal Information with trusted third parties (with whom we have a contractual relationship) where we have retained them to provide services that you or our clients have requested, and to perform maintenance or respond to technical incidents affecting our services.

Where we disclose Personal Information to third parties, we require minimum standards of confidentiality and data protection from such third parties and the Information Security Handbook applies.

Sub-contractors and therefore third-party sub-processors of Kineo, to provide support services as may be required from time to time:

Legal name and registered address	Purpose of processing	Categories of personal data processed	Where personal data is processed	Period of retention
Think Innovations PTY LIMITED Level 35, Tower One Barangaroo International Towers Sydney, 100 Barangaroo Avenue, Sydney NSW, 2000 Australia	To support provision of the Service, including Service Desk, in an efficient manner	The personal data listed in the Agreement	Australia	During the Agreement /SOW Term
Compass Offices 16th floor, 6789 Ayala Avenue, Makati City 1206, Philippines	To support provision of the Service in an efficient manner	The personal data listed in the Agreement	Philippines	During the Agreement /SOW Term

Third-party sub-processors of Kineo, to provide support services as may be required from time to time:

Legal name	Purpose of processing	Categories of personal data processed	Where personal data is processed	Period of retention
Microsoft Azure	The provision of hosting services	The personal data listed in the Agreement	As per Agreement	During the Agreement /SOW Term
Sisense Ltd privacy@sisense.com	To enable the provision of Kineo Analytics	The personal data listed in the Agreement	As per Agreement	During the Agreement /SOW Term
Rapid BI – Sisense partner	To provide assistance with Sisense implementation, maintenance. monitoring and minor changes with Business Intelligence	The personal data listed in the Agreement	As per Agreement	During the Agreement /SOW Term
Cloudflare privacyquestions@cloudflare.com	To provide enhanced internet security	The personal data listed in the Agreement	As per Agreement	During the Agreement /SOW Term
Atlassian Pty Ltd privacy@atlassian.com	To support the provision of the Service in an efficient manner, including Service Desk	The personal data listed in the Agreement	As per Agreement	During the Agreement /SOW Term
Individual freelancers engaged by Kineo.	To support provision of the Service in an efficient manner	The personal data listed in the Agreement	As per Agreement	The personal data listed in the Agreement

Sub-contractors which are part of the Mindtools Business:

Legal name and registered address	Purpose of processing	Categories of personal data processed	Where personal data is processed	Period of retention
City and Guilds Kineo Limited t/a Kineo, Floor 5 Northspring 21-23 Wellington St, Leeds, England, LS1 4DL	To support provision of the Service in an efficient manner	The personal data listed in the Agreement	UK	During the Agreement /SOW Term
KINEO MIND TOOLS PTY LTD t/a Kineo, c/- Bilateral Solutions Pty Ltd, 1/575 Darling Street, Rozelle NSW 2039	To support provision of the Service in an efficient manner	The personal data listed in the Agreement	Australia	During the Agreement /SOW Term
Kineo Group Inc. t/a Kineo, 625 W Adams Street #20-136, Chicago IL 60661	To support provision of the Service in an efficient manner	The personal data listed in the contract	USA	During the Agreement /SOW Term
Kineo South Africa Pty Ltd t/a Kineo, 9 Kinross St, Germiston Gauteng 1401, South Africa	To support provision of the Service in an efficient manner	The personal data listed in the contract	South Africa	During the Agreement /SOW Term
Knowledge and Interactive Services Mexico SRL de CV t/a Kineo, No. 315, Roma Norte, Cuauhtémoc, 06700 Ciudad de Mexico, Ciudad de Mexico, Mexico	To support provision of the Service in an efficient manner	The personal data listed in the contract	Mexico	During the Agreement /SOW Term
Knowledge and Interactive Services Argentina SRL, t/a Kineo Arevalo 1462 Oficina 1 Ciudad Autónoma de Buenos Aires, Buenos Aires City, CP 1414 Argentina	To support provision of the Service in an efficient manner	The personal data listed in the contract	Argentina	During the Agreement /SOW Term

Security

Kineo holds various industry and international standards see our certification pages here: Certifications | Kineo AU,UK and US

The steps we take to secure the Personal Information we hold include ICT security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, personnel security and training and workplace policies.

Where you have a username or password (or other identification information) which enables you to access certain services or parts of any one of our Websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Payment security

We process payments using PayPal/Stripe and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.

Website security

While we strive to protect the Personal Information and privacy of users of our Websites, we cannot guarantee the security of any information that you disclose online, and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post.

You can also help to protect the privacy of your Personal Information by maintaining the confidentiality of your account (including your password), and by ensuring that you log out of your account on the relevant Website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.

United Kingdom / European Union
If you believe that your data protection rights may have been breached, please send an email to dpt@kineo.com or write to Data Protection, City and Guilds Kineo Limited t/a Kineo, Floor 5 Northspring 21-23 Wellington St, Leeds, England, LS1 4DL.

You may lodge a complaint to the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns/ for more information on how to report a concern to the UK Information Commissioner’s Office.

Argentina, Australia and United States, Mexico
If you believe that your data protection rights may have been breached, please send an email to dpt@kineo.com.

Australia
If you have a complaint about how we have handled your Personal Information, please contact our Privacy Officer at privacy@kineo.com.au, who will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week. We will endeavour to acknowledge receipt of the data protection and Privacy Complaint within 5 business days of receiving it and to complete our investigation into your complaint in a timely manner.

In most cases, we expect that complaints will be investigated, and a response provided within 30 days of receipt of the Privacy Complaint Form. If our investigation may take longer, we will let you know.

If you are unhappy with our response, you can refer your complaint to the Office of the Australian Information Commissioner or, in some instances, other regulatory bodies, such as the Australian Communications and Media Authority. E-mail us at privacy@kineo.com.au.

New Zealand
If you are unhappy with our response, you can refer your complaint to the Office of the Privacy Commissioner Please visit https://www.privacy.org.nz/your-rights/making-a-complaint/ for more information on how to report a concern. E-mail us at privacy@kineo.com.au.

Contact

UK/European Union, USA, Mexico and Argentina
If you have any queries about this privacy notice, the way Kineo and Mindtools businesses process personal data, please send an email to dpt@kineo.com or write to Data Protection, City and Guilds Kineo Limited t/a Kineo, Floor 5 Northspring 21-23 Wellington St, Leeds, England, LS1 4DL.

Australia & New Zealand
If you have any queries about this privacy notice, please contact our Privacy Officer at privacy@kineo.com.au or write to us at: Kineo Mind Tools Pty Ltd (Kineo), c/- Bilateral Solutions Pty Ltd, 1/575 Darling Street, Rozelle NSW 2039.

For online enquiries you can email privacy@kineo.com.au or reach us via telephone: +61 1300 303 318

Changes to our privacy notice

Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.

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