Privacy Policy

We may collect and retain the following personal information when you use our Site:

• Account information — your name, email address and password when you create an account, and any optional details you choose to add, such as a profile photo, phone number, address and country
• Social sign-in information — if you sign in with Google, Facebook, LinkedIn, Apple or X, the basic profile details that provider shares with us (usually your name, email address and profile photo). We do not receive your password for those services
• Professional information — your employer or business name, profession and position where you provide them
• Purchase information — records of the courses you buy, the amounts paid and your billing details. Card payments are processed by Stripe; we do not receive or store your full card number
• Learning records — your enrolments, course progress, quiz and assessment results, certificates of completion, and any assignments, comments, discussion posts or other content you submit on the Site
• Communications — records of your enquiries, expressions of interest, newsletter sign-ups and correspondence with us
• Technical information — collected automatically, including IP address, browser and device type, pages visited and time on site, through cookies and similar technologies (see section 7)

We do not ask for sensitive information, including health information, and our forms are not designed to collect it. Please do not include your own health information, or any information that could identify a patient, in assignments, discussions or other content you submit on the Site.

We will only collect information by lawful and fair means, and where reasonably practicable, we will collect personal information directly from you rather than from a third party. If we receive unsolicited personal information that we could not have lawfully collected, we will destroy or de-identify that information as soon as practicable.

We collect personal information to:

• create and manage your account and give you access to the courses you have enrolled in
• process payments and keep financial records
• track your progress and issue certificates of completion
• respond to your enquiries and provide learner support
• send you service messages about your account, purchases and courses
• send you occasional articles, course news and updates where you have consented
• manage our professional relationships and business operations
• improve our courses and Site and understand how learners engage with our content, using aggregated or de-identified information where practicable
• comply with our legal obligations

Except to the extent necessary for the operation of our business, as authorised by you, or as required by law, we will not use or disclose your personal information for any other purpose. Restrictions on use and disclosure do not apply where we de-identify the information.

We may disclose your personal information to third-party service providers who assist us in operating our business, including:

• LearnWorlds (LearnWorlds (CY) Ltd) — the learning platform that hosts the Site, your account, course content and learning records
• Stripe (Stripe, Inc. and its affiliates, including Stripe Payments Australia Pty Ltd) — our payment processor
• Mailgun (Mailgun Technologies, Inc., United States) — used to deliver emails sent from the Site
• Google, Facebook (Meta), LinkedIn, Apple and X — only if you choose to sign in using one of these services
• Podio (Citrix Systems Inc., United States) — our customer relationship management platform, used to manage contacts and enquiries
• Cursor (Anysphere, Inc., a subsidiary of SpaceXAI, United States) — AI-assisted software development tools used in the operation and maintenance of our digital services
• Grok (xAI / SpaceXAI, United States) — AI software used to assist with business operations and content
• Claude (Anthropic PBC, United States) — AI software provided by Anthropic, a public benefit corporation focused on AI safety and responsible development, used to assist with business operations and content
• Microsoft 365 Copilot (Microsoft Corporation, United States) — AI-assisted productivity tools used in the operation of our business
• Third-party hosting and infrastructure providers — who may store data as part of providing services to us; these providers are not permitted to access, use, or disclose your information except to the limited extent necessary to provide those services

We may also disclose personal information where required or authorised by law.

If you enrol in a course through, or at the request of, your employer or another organisation, we may share your enrolment, progress and completion information with that organisation.

We will not sell your personal information to third parties, or intentionally disclose it to third parties except as described in this Policy or with your consent.

Some of the third-party services listed above store and process personal information outside Australia, including in the United States and the European Union. Before disclosing your personal information to overseas recipients, we take reasonable steps to ensure those recipients handle your information in a manner consistent with the Australian Privacy Principles. By using our Site, you acknowledge that your information may be transferred to and processed in countries outside Australia, and that the overseas recipient may not be subject to privacy obligations equivalent to those in Australia.

Where possible, data storage and processing are configured to remain in Australia. However, this cannot always be guaranteed given the nature of the third-party platforms we use.

If you have subscribed to our newsletter, registered an expression of interest, or otherwise agreed to hear from us, we may use your name and email address to send you course news, articles and updates. You may unsubscribe at any time by clicking the unsubscribe link in any marketing email, by changing your preferences in your account, or by contacting us at admin@douglasfahlbusch.com. We will not use your personal information for direct marketing without your consent, and we will honour opt-out requests promptly.

Unsubscribing from marketing does not stop service messages about your account, purchases or enrolled courses.

Our Site uses cookies — small text files stored on your device — to support essential functions such as signing in and payments, to remember your preferences, and to collect analytics data. When you visit our Site, our systems may record information about your access and use of the Site, including pages visited and time spent (clickstream data). This data is used to understand traffic patterns and improve the Site.

You can choose which non-essential cookies to accept using our cookie banner, and you can disable cookies through your browser settings, though this may affect some Site functionality, including signing in. For more detail, see our Cookie Policy at www.healthevo.pro/cookies.

If we or any authority suspect unauthorised access to the Site, we may gather and use more extensive information regarding access or attempted access for the purposes of prevention, detection, investigation, or prosecution.

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. Our Site uses HTTPS encryption for all data transmission, and access to our systems is restricted to authorised personnel. Where possible, data is encrypted both in transit and at rest.

You are responsible for keeping your account password confidential. Please tell us promptly if you believe your account has been accessed without your permission.

No internet transmission can be guaranteed completely secure. We cannot guarantee the security of information you transmit to us, and you do so at your own risk.

We keep your account and learning records while your account is active, so that you can continue to access your courses and certificates. We keep financial records for as long as the law requires. When we no longer need your personal information, we will take reasonable steps to permanently destroy or de-identify it. Our backup procedures may make it impractical to locate and destroy all copies of information stored offline, and you consent to our continued retention of information in those circumstances.

Our Site may contain links to third-party websites. If you submit information to any site accessed through a link from our Site, the privacy principles applying to that site are outside our control. We encourage you to review the privacy policy of any third-party site before submitting information to it.

You can view and update most of your account details yourself by signing in to the Site. You also have the right to request access to the personal information we hold about you, and to ask us to correct any inaccuracies. To make a request, or to ask us to close your account and delete your information, please contact us at admin@douglasfahlbusch.com with adequate proof of your identity. Closing your account will end your access to courses and certificates on the Site.

We will respond to access and correction requests within a reasonable time in accordance with the Privacy Act 1988 (Cth). We will correct errors in your personal information upon receipt of written evidence satisfying us that a correction is required. There is generally no charge for access requests, though in limited circumstances a reasonable fee may apply where the cost of retrieval is significant.

It is not practicable to use the Site anonymously or using a pseudonym, because an account, course enrolment and certificate of completion must be linked to you. Where data fields require your name or personal details, accurate completion is a requirement of the relevant process.

The Site is intended for adults. Persons under the age of 18 should use the Site only with the supervision and consent of a parent or guardian.

If you believe we have not complied with our privacy obligations, please contact us in the first instance at admin@douglasfahlbusch.com. We will investigate your complaint and respond within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.

We may update this Privacy Policy from time to time. The current version will always be available at www.healthevo.pro/privacy. We encourage you to review this Policy periodically. Your continued use of the Site after any changes constitutes acceptance of the updated Policy.

For any privacy-related questions or requests, please contact:

HealthEVO, Douglas Fahlbusch Healthcare Consulting and DiseaseCare to HealthyCare
(Perioperative Solutions Pty Ltd atf Perioperative Solutions Trust, ABN 34 149 623 950)
C/O APSO The Watson, 33 Warwick Street, Walkerville SA 5081, Australia
Email: admin@douglasfahlbusch.com
Website: www.healthevo.pro