Privacy

Keyframe Health (ABN 77 695 846 989) ("we", "us", "our") is an online education provider committed to protecting the privacy of our students, course participants, and website visitors.

This Privacy Policy explains how we collect, use, hold, disclose and protect your personal information when you visit our website at keyframehealth.com.au (the "Site"), enrol in or participate in our courses and educational programs, or otherwise interact with us.

We are bound by the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs") contained in Schedule 1 of that Act, as amended from time to time including by the Privacy and Other Legislation Amendment Act 2024.

Please read this Privacy Policy carefully. By using our Site or services, you acknowledge that you have read and understood this policy. This Privacy Policy should be read together with our Cookie Policy.

3.1 Personal Information
"Personal information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, as defined in the Privacy Act 1988 (Cth).

As an education provider, we may collect the following types of personal information:

Type of Information	Examples
Identity information	Full name, date of birth, title, gender (if provided)
Contact information	Email address, telephone number, postal address
Professional information	Job title, profession, employer, professional registration or membership number, years of experience
Account information	Username, password (encrypted), account preferences and settings
Enrolment information	Courses enrolled in, enrolment date, enrolment status, referral source
Learning and progress data	Course completion status, assessment results, quiz scores, certificates issued, time spent on learning activities, lesson progress
Transaction information	Payment records, purchase history, invoices, refund requests
Communications	Emails, messages, discussion board posts, live chat transcripts, support enquiries
Technical information	IP address, browser type and version, device type, operating system, time zone setting
Usage information	Pages visited, links clicked, videos watched, time spent on pages, referring URLs
Marketing preferences	Preferences for receiving marketing and communications from us

3.2 Sensitive Information
We do not routinely collect sensitive information (such as health information, racial or ethnic origin, political opinions, religious beliefs, or criminal record) as part of our standard education services.

If you voluntarily disclose sensitive information to us — for example, by advising us of an accessibility requirement or learning support need — we will handle that information with the additional care required by APP 3 and will only use or disclose it for the purpose for which it was provided and as otherwise permitted by law.

We will always seek your express consent before collecting sensitive information, unless required by law.

3.3 Financial Information
We collect information necessary to process payments for our courses and services, including your name and billing address. Payment card transactions are processed by Stripe, a PCI-DSS compliant third-party payment processor. We do not store your full credit or debit card numbers on our systems. Stripe's privacy policy is available at stripe.com/au/privacy.

3.4 Students Under 18
Some of our courses may be suitable for students under the age of 18. If you are under 18, please ensure a parent or guardian has reviewed this Privacy Policy and consents to your enrolment and our handling of your personal information.

We do not knowingly collect personal information from children under the age of 13 without verifiable parental consent. If you believe a child under 13 has provided us with personal information without appropriate consent, please contact us immediately at contact@keyframehealth.com.au.

4.1 Information You Provide Directly
We collect personal information that you voluntarily provide when you:
• Create an account or register on our Site
• Enrol in or purchase a course or educational program
• Complete a profile, form, survey, or quiz
• Participate in course discussion boards, live sessions, or webinars
• Contact us with an enquiry, feedback, or complaint
• Subscribe to our mailing list or newsletter
• Apply for a certificate, credential, or completion record
• Communicate with us by email, telephone, or live chat

4.2 Information Collected Automatically
When you visit our Site or use our learning platform, we automatically collect certain technical and usage information through cookies and similar technologies. This includes your IP address, browser type, device information, pages visited, course progress, and how you navigated our Site and learning platform. Please refer to our Cookie Policy for full details.

4.3 Information From Third Parties
We may occasionally receive personal information about you from third parties, including:
• Payment processors (such as Stripe) confirming that a transaction has been completed
• Employers or organisations that have purchased access to our courses on your behalf
• Analytics providers supplying aggregated or anonymised usage data
• Marketing platforms where you have consented to share your information with us

We collect and use your personal information only where we have a lawful basis to do so. We use your personal information for the following purposes:

Purpose	Reason
To create and manage your student account	Necessary to perform our contract with you
To process your enrolment and deliver courses	Necessary to perform our contract with you
To track your learning progress and issue certificates	Necessary to perform our contract with you
To process payments and manage billing	Necessary to perform our contract with you
To communicate with you about your enrolment or courses	Necessary to perform our contract with you
To respond to your enquiries, feedback, and complaints	Legitimate interest / legal obligation
To provide learning support and accessibility accommodations	Legitimate interest
To send service updates, course announcements, and notices	Legitimate interest (you may opt out of non-essential messages)
To send marketing and promotional communications	Your consent (you may withdraw at any time)
To improve and develop our courses and platform	Legitimate interest
To conduct internal analytics and reporting	Legitimate interest
To issue and verify certificates and credentials	Legitimate interest / contractual
To comply with our legal obligations	Legal obligation
To detect and prevent fraud or security incidents	Legitimate interest / legal obligation
To manage corporate enrolments from employers	Necessary to perform our contract

We will not use your personal information for any purpose that is incompatible with the purpose for which it was collected, unless you have consented or we are required or authorised to do so by law.

If your employer or an organisation has enrolled you in one of our courses or purchased access on your behalf (a "corporate enrolment"), please be aware of the following:

• We may share your enrolment status, course progress, completion status, and assessment results with the sponsoring organisation
• The sponsoring organisation may have access to a dashboard showing learning activity for participants they have enrolled
• We will only share the information reasonably necessary for the organisation to manage and report on its training investment

If you have questions about what information your employer can see, please contact us at contact@keyframehealth.com.au or speak with your employer directly.

We may send you marketing communications about our courses, programs, promotions, and events that we think may interest you. We will only do this where you have:
• Expressly consented to receive marketing from us; or
• Previously enrolled in our courses and would reasonably expect to receive similar communications (inferred consent), subject to your right to opt out at any time

All marketing emails we send comply with the Spam Act 2003 (Cth) and include a clear and functional unsubscribe mechanism. You can opt out at any time by:
• Clicking the "unsubscribe" link in any marketing email we send
• Contacting us at contact@keyframehealth.com.au

Opting out of marketing will not affect our ability to send you transactional or service messages such as enrolment confirmations, course access details, payment receipts, or certificate notifications.

8.1 When We Share Your Information
We do not sell your personal information to third parties. We may disclose your personal information to the following categories of recipients for the purposes described in this policy:

Recipient	Purpose
Payment processors (Stripe)	To process course payments and manage billing
Learning management system (LMS) provider	To host and deliver our online courses and track learning progress
Cloud hosting and infrastructure providers	To host our Site and securely store data
Video hosting providers (Vimeo)	To deliver video-based course content
Analytics providers (Google Analytics)	To understand how our Site and courses are used
Email and marketing platform providers	To manage and send course and marketing communications
Certificate and credentialling tools	To issue, store, and verify course completion certificates
Employers and sponsoring organisations	To report on learning progress for corporate enrolments (see Section 6)
Professional advisers	Legal, accounting, and insurance services where required
Regulatory authorities and law enforcement	Where required or authorised by law

We require all third-party recipients to respect the security of your personal information and to treat it in accordance with applicable law. We do not allow third parties to use your personal information for their own purposes.

8.2 Disclosure Required by Law
We may disclose your personal information where required or authorised by law, including in response to a valid court order, subpoena, or regulatory requirement. Where possible and legally permitted, we will notify you before making such a disclosure.

8.3 Business Transfers
If we sell, transfer, or restructure all or part of our business, your personal information may be transferred to the new owner as part of that transaction. We will take reasonable steps to ensure the new owner is bound by privacy obligations at least equivalent to those in this policy and, where practicable, will notify you in advance.

Some of our third-party service providers are based outside Australia and may process your personal information overseas. Before disclosing personal information to overseas recipients, we take reasonable steps under APP 8 to ensure they do not breach the APPs in relation to your information.

We currently use service providers in the following countries:

Country	Service Providers	Safeguards
United States	Google LLC (Analytics, Ads), Meta Platforms Inc. (Advertising), Stripe Inc. (Payments), Cloudflare Inc. (Security), Vimeo LLC (Video), [INSERT LMS provider if US-based]	Data Processing Agreements; Standard Contractual Clauses; Privacy Framework certifications; IP anonymisation enabled (Google Analytics)

By using our Site and services, you acknowledge that your personal information may be transferred to and processed in countries whose privacy laws may differ from those in Australia. We take reasonable steps to protect your information, but cannot guarantee that overseas recipients will comply with the APPs in all circumstances.

10.1 Right to Access
You have the right to request access to the personal information we hold about you, including your enrolment records and learning data. Please contact our Privacy Officer at contact@keyframehealth.com.au. We will respond within 30 days and provide access free of charge.

In limited circumstances permitted by the Privacy Act, we may decline an access request (for example, where it would unreasonably impact another individual's privacy). If we decline, we will provide written reasons.

10.2 Right to Correction
If any personal information we hold about you is inaccurate, out-of-date, incomplete, or misleading, you have the right to request correction. We will take reasonable steps to correct the information within 30 days. If we decline, we will provide written reasons and you may request that a note of the correction sought be associated with your record.

10.3 Right to Withdraw Consent
Where we rely on your consent to process your personal information (for example, for marketing), you may withdraw that consent at any time by contacting us at contact@keyframehealth.com.au or using the unsubscribe link in any marketing email. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

10.4 Right to Make a Complaint
If you believe we have handled your personal information in breach of the Privacy Act, you have the right to make a complaint. Please see Section 14 for our complaints process.

We take reasonable steps to protect your personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. Our security measures include:

• Encryption of data in transit using TLS (Transport Layer Security)
• Encryption of data at rest for sensitive information
• Role-based access controls limiting who within our organisation can access personal information
• Secure, password-protected account access for all students
• Regular security assessments of our platform and third-party providers
• Staff training on privacy and data security obligations
• Secure deletion or de-identification of personal information when no longer needed

While we take all reasonable steps to protect your information, no method of internet transmission or electronic storage is completely secure. We cannot guarantee absolute security. If you suspect your account has been compromised, please contact us immediately at contact@keyframehealth.com.au.

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Our general retention periods are:

Type of Information	Retention Period
Student account and profile information	Duration of account, plus 2 years after account closure or last activity
Enrolment and course progress records	7 years from the date of enrolment (to support certificate verification and compliance)
Course completion certificates	Indefinitely, or until you request deletion (to support ongoing credential verification)
Assessment results and quiz data	7 years from completion
Transaction and payment records	7 years to comply with tax and financial record-keeping obligations
Marketing preferences and consent records	Until you withdraw consent or opt out, plus 1 year for compliance purposes
Technical and usage logs	12 months
Support and correspondence records	3 years from the date of last correspondence
Corporate enrolment reporting data	Duration of the corporate agreement, plus 2 years

When personal information is no longer required, we will take reasonable steps to securely destroy or permanently de-identify it in accordance with APP 11.2.

We are subject to the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). If we experience an eligible data breach — that is, a breach likely to result in serious harm to individuals whose personal information is involved — we are required to:

• Notify the Office of the Australian Information Commissioner (OAIC) as soon as practicable
• Notify affected individuals directly, or where that is not reasonably practicable, publish a notice on our Site

We have internal procedures to detect, contain, assess, and respond to data breaches in a timely manner. If you suspect that your personal information has been involved in a data breach, please contact us immediately at contact@keyframehealth.com.au.

14.1 How to Make a Complaint
If you believe we have mishandled your personal information or breached the Privacy Act or the APPs, please contact us first so we can attempt to resolve your concern.

Step 1 — Contact us:
Please contact our Privacy Officer in writing:
Email: contact@keyframehealth.com.au

Step 2 — We will investigate:
We will acknowledge your complaint within 5 business days and aim to provide a substantive response within 30 days. For complex matters we may require additional time and will keep you informed.

Step 3 — External escalation:
If you are not satisfied with our response, or we have not responded within 30 days, you may lodge a complaint with the OAIC:

Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au
Phone: 1300 363 992
Online: www.oaic.gov.au/privacy/privacy-complaints
Post: GPO Box 5218, Sydney NSW 2001

We may update this Privacy Policy from time to time. We will notify you of material changes by posting an updated policy on our Site with a new "Last updated" date, and where appropriate, by email notification or a notice on our Site or platform.

We encourage you to review this Privacy Policy periodically. Your continued use of our Site or platform after changes have been posted constitutes acceptance of non-material updates. For material changes affecting how we handle your personal information, we will seek your consent where required by law.

Keyframe Health acknowledges the Kaurna people as the Traditional Custodians of the Adelaide Plains, and pays respect to Elders past and present. We acknowledge Aboriginal and Torres Strait Islander peoples as the First Peoples of Australia and Traditional Custodians of Country throughout Australia, and recognise the ongoing strength, resilience, and contribution of First Nations peoples, cultures, and communities.

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Privacy Policy

1. Introduction

2. About Us and How to Contact Us

3. What Personal Information We Collect

4. How We Collect Your Personal Information

5. How We Use Your Personal Information

6. Corporate and Employer-Sponsored Enrolments

7. Direct Marketing

8. Disclosure of Your Personal Information

9. Overseas Disclosure of Personal Information

10. Your Privacy Rights

11. How We Protect Your Information

12. How Long We Keep Your Information

13. Notifiable Data Breaches

14. Privacy Complaints

15. Cookies and Online Tracking

16. Third-Party Websites and Links

17. Changes to This Privacy Policy

18. Governing Law

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