1. About this Policy

This Privacy and Cookies Policy explains how SenseUp collects, holds, uses, discloses, protects and manages personal information when people use www.senseup.org, purchase or access digital products, join courses or communities, attend online or in-person training, subscribe to communications, contact SenseUp, or otherwise interact with the SenseUp brand.

SenseUp is based in Australia and aims to handle personal information consistently with the Privacy Act 1988 (Cth) and the Australian Privacy Principles where they apply. Additional privacy rights may apply to people in other countries, including under the EU General Data Protection Regulation and UK data protection law.

2. Who is responsible for your information

The organisation responsible for the processing described in this Policy is SenseUp Pty Ltd, ABN 86 660 099 570, an Australian private company active from 13 June 2022 and operating the SenseUp and SenseUp Training brands from Queensland 4227, Australia.

Privacy Contact: Chief Executive Officer, Kerry Evetts

Email: [email protected]

Business location: Queensland 4227, Australia

3. Scope

This Policy applies to personal information handled by SenseUp through the Website, course and community platforms, email, forms, surveys, online meetings, payments, events, social media and direct communications.

SenseUp may also provide a shorter collection notice at the point personal information is requested. That notice should be read together with this Policy.

It does not govern the independent privacy practices of a third party, including a payment processor, venue, event host, employer, social network or external website. Their privacy policies should be reviewed separately.

4. Personal information we may collect

• Identity and contact information, such as name, email, telephone number, country, postal address and billing details.
• Professional information, such as occupation, employer, professional registration, qualifications, areas of practice, learning needs and eligibility for profession-restricted training.
• Account and course information, such as login details, enrolments, access dates, progress, attendance, assessment results, certificates, community activity and support history.
• Transaction information, such as products purchased, payment status, invoices, refunds, currency and tax information. SenseUp does not ordinarily receive or store full payment-card details.
• Communications, feedback and content, including emails, form responses, survey answers, questions, comments, testimonials and materials voluntarily submitted.
• Event information, such as attendance, dietary requirements, accessibility requirements, emergency contact information and limited health or injury information voluntarily provided for safe participation.
• Images, audio and video where an Event or online session is recorded, or where a person gives permission for a photograph, testimonial or case study.
• Technical and usage information, such as IP address, device type, browser, operating system, approximate location, referral source, pages viewed, links clicked, login activity and cookie identifiers.
• Marketing preferences, consent records, subscription status and interactions with communications.
• Information reasonably required to detect fraud, unauthorised account sharing, misuse of Content, impersonation, security incidents, or suspected infringement or misuse of SenseUp's brand and intellectual property.

5. How we collect personal information

• directly from you when you complete a form, create an account, purchase, enrol, attend, communicate, submit content or change preferences;
• from an organisation purchasing or coordinating training for you;
• from event hosts, venues or referral partners where appropriate and lawful;
• automatically through the Website, course platform, cookies, analytics and security tools;
• from payment, email, video-conferencing, learning-management and customer-support providers;
• from public professional sources where reasonably necessary to verify eligibility, registration, authorship, brand use or professional representations;
• from another person where you have authorised the disclosure or where collection is otherwise permitted by law.

6. Why we use personal information

SenseUp may use personal information to:

• provide, administer and support purchases, accounts, Digital Products, courses, memberships, Events, communities and certificates;
• process payments, instalments, refunds, invoices, taxes and financial records;
• verify identity, professional eligibility, attendance, completion or competency requirements;
• respond to enquiries, provide technical support and manage complaints or disputes;
• communicate service information, schedule changes, access instructions and administrative notices;
• personalise learning support and improve Content, services, accessibility and participant experience;
• conduct surveys, quality assurance, analytics, research and business planning using aggregated or de-identified information where practicable;
• send marketing where permitted and manage consent and unsubscribe requests;
• maintain security, prevent fraud, investigate unauthorised access or account sharing and protect Participants;
• protect and enforce SenseUp's contractual rights, copyright, trade marks, brand identity, confidential information and other legitimate interests, including investigating suspected misuse, impersonation, unauthorised distribution or misleading representations;
• comply with legal, regulatory, tax, insurance, professional and recordkeeping obligations;
• establish, exercise or defend legal claims and obtain professional advice;
• support a genuine business transaction, restructure or transfer, subject to appropriate confidentiality and legal safeguards.

7. Legal bases for international processing

Where the EU GDPR, UK GDPR or another law requires a legal basis, SenseUp relies on one or more of the following:

• performance of a contract or steps requested before entering a contract;
• compliance with a legal obligation;
• consent, including for certain marketing, sensitive information, recordings or non-essential cookies;
• legitimate interests, such as delivering and improving services, maintaining security, preventing misuse, protecting intellectual property and brand integrity, and managing business operations, where those interests are not overridden by individual rights;
• establishment, exercise or defence of legal claims;
• another basis available under the applicable law.

8. Sensitive information

SenseUp seeks to minimise collection of sensitive information. Limited health, disability, injury, dietary, professional-membership or other sensitive information may be collected where it is reasonably necessary for safe and accessible participation, eligibility or another disclosed purpose. SenseUp will seek consent where required and will restrict access to those who need the information.

Participants should not submit identifiable client, child or family health information through courses, communities or case discussions. Case material should be appropriately de-identified and handled in accordance with professional and legal obligations.

9. Payments

Payments are processed by third-party payment providers. Depending on the checkout method, providers may include Kajabi Payments and associated processors, Stripe, PayPal, Apple Pay, Google Pay or another provider shown at checkout. These providers process payment credentials under their own terms and privacy policies. SenseUp ordinarily receives transaction confirmation and limited billing information rather than full card details.

10. Cookies and similar technologies

SenseUp and its service providers may use cookies, pixels, local storage, tags and similar technologies. These technologies may be used for:

• strictly necessary functions, including security, checkout, account login and course access;
• preferences and functionality;
• audience measurement, analytics and service improvement;
• marketing, attribution, retargeting and social-media integration where permitted.

Where required by law, non-essential cookies will be used only after consent. Cookie choices can be managed through the Website consent tool and browser settings. Withdrawing consent does not affect processing that was lawful before withdrawal, but some Website features may work differently.

The provider mix may include Kajabi, Google services, Meta services and other analytics, advertising or social platforms configured by SenseUp. The cookie consent tool should contain the current provider and cookie details.

11. Marketing communications

SenseUp may send newsletters, educational updates and offers where the recipient has consented or where another lawful basis applies. Commercial electronic messages will identify the sender and include a functional unsubscribe method. An unsubscribe request will be processed within the period required by applicable law.

Unsubscribing from marketing does not prevent necessary service communications about an existing purchase, account, Event, safety issue or legal notice.

12. When we disclose personal information

SenseUp may disclose personal information to:

• course, website, community, video-conferencing, email, customer-support, survey, analytics and cloud-hosting providers;
• payment processors, banks, accountants and financial service providers;
• Event venues, hosts, contractors and presenters where necessary to administer an Event;
• professional advisers, insurers, auditors and legal representatives;
• regulators, courts, law-enforcement bodies or other authorities where required or authorised by law;
• a purchaser, investor or successor in connection with a genuine business transaction, subject to appropriate safeguards;
• another party with the individual's consent or at the individual's direction.

SenseUp does not sell personal information for money. Some advertising or analytics activities may be treated as a sale or sharing under particular privacy laws. Where those laws apply, SenseUp will provide any required notice and opt-out mechanism.

13. Overseas processing and disclosure

SenseUp serves an international audience and uses providers that may store or process information outside Australia. Personal information may be accessed or processed in Australia, the United States and other countries in which SenseUp's service providers, contractors, event partners or participants operate.

Where Australian Privacy Principle 8 applies, SenseUp will take reasonable steps before an overseas disclosure to ensure appropriate handling, unless an exception applies. Where EU or UK transfer rules apply, SenseUp will use an available transfer mechanism and supplementary safeguards where required.

14. Security

SenseUp uses reasonable administrative, technical and physical safeguards appropriate to the nature of the information and the size and operations of the business. These may include access controls, strong authentication, provider security settings, encryption in transit, backups, staff or contractor confidentiality, record minimisation and incident response procedures.

No internet transmission or storage system is completely secure. Participants should use unique passwords, protect account credentials and notify SenseUp promptly of suspected unauthorised access.

15. Retention and deletion

Personal information is retained only for as long as reasonably necessary for the purposes described in this Policy, including service delivery, access periods, certification, dispute management and legal, tax, insurance or professional recordkeeping.

• Financial and transaction records are retained for the period required by applicable law.
• Course, attendance and certificate records may be retained to verify completion and respond to professional queries.
• Marketing information is retained until consent is withdrawn or the information is no longer required, with limited suppression records kept to respect opt-outs.
• Recordings are retained for the access period or purpose stated when recorded, unless a longer period is reasonably required and lawful.
• Information that is no longer required is securely deleted or de-identified where reasonably practicable.

16. Access, correction and account choices

A person may request access to personal information held about them and ask for inaccurate, out-of-date, incomplete or misleading information to be corrected. Requests should be sent to [email protected]. Identity may need to be verified before information is released or changed.

Access may be refused or limited where permitted by law, including where disclosure would unreasonably affect another person's privacy, reveal confidential evaluative material, prejudice an investigation or legal proceeding, or be unlawful. Reasons will be provided where required.

17. Additional rights for people outside Australia

Where applicable, individuals may have additional rights, including the right to request deletion, restrict or object to processing, withdraw consent, receive portable data, object to direct marketing, and complain to a local data-protection authority. These rights are subject to legal conditions and exceptions.

For EEA and UK individuals, requests may be made through [email protected]. SenseUp will respond within the period required by the applicable law. If SenseUp is required to appoint an EU or UK representative, the representative's details will be added to this Policy.

18. Children

SenseUp's training and professional-development services are primarily directed to adults and professionals, not children. SenseUp does not knowingly seek personal information directly from children through the Website. If a parent or guardian believes a child has provided personal information without appropriate permission, they should contact SenseUp.

19. Photographs, recordings and testimonials

SenseUp will provide notice where an Event or session is recorded. Where a recording is necessary to deliver the purchased service, the recording will be used and retained for that purpose. Separate permission will be obtained where reasonably required for promotional use of a person's identifiable image, voice, testimonial or story.

Permission for future promotional use may be withdrawn by contacting SenseUp. Withdrawal will not ordinarily require recall of material already lawfully published or printed, but SenseUp will stop new use where reasonably practicable.

20. Automated decision-making

SenseUp does not currently make decisions producing legal or similarly significant effects solely through automated processing. Routine automation may be used for email sequences, course access, fraud indicators, segmentation and administrative workflows. If SenseUp introduces significant automated decision-making, this Policy and the relevant collection notices will be updated before that use where required.

21. Data breaches

SenseUp maintains an incident-response process. If a data breach is likely to result in serious harm and the Australian Notifiable Data Breaches scheme applies, SenseUp will notify affected individuals and the Office of the Australian Information Commissioner as required. Other regulators or individuals will be notified where required by applicable law.

22. Third-party links and social media

The Website may link to third-party sites or social platforms. SenseUp does not control their privacy practices. Information posted publicly on social media may be visible, copied or used by others according to the platform's rules and the user's settings.

23. Complaints

1. Contact the Privacy Contact at [email protected] and describe the concern.
2. SenseUp will acknowledge and investigate the complaint within a reasonable period and may request further information.
3. If the complaint is not resolved, an Australian complainant may contact the Office of the Australian Information Commissioner where the Privacy Act applies. People in other jurisdictions may also contact their local privacy or data-protection authority.

24. Changes to this Policy

SenseUp may update this Policy to reflect changes in law, technology, providers or practices. The current version will be published on the Website with the updated date. Material changes will be notified where required or reasonably appropriate.

25. Contact

Privacy Contact: Chief Executive Officer, Kerry Evetts

SenseUp Pty Ltd

Queensland 4227, Australia

Email: [email protected]

Website: www.senseup.org