1. Scope of this policy

This policy applies to personal information handled through the Phil Adair Training website and related communications.

In this policy, “Phil Adair Training”, “we”, “us” and “our” refer to the operator of philadairtraining.com. “You” refers to a website visitor, subscriber, client, prospective client, contributor or other person who communicates with us.

This website is operated from Australia. Privacy requirements from other jurisdictions may also apply when the website is accessed or services are offered outside Australia.

2. Personal information we may collect

The information collected depends on how you use the website and whether you communicate directly with us.

Please do not send passwords, account credentials, government identity documents, health information or unnecessary sensitive business or financial information through an initial enquiry.

3. How information is collected

Personal information may be collected when you:

• send an email or use a website contact form;
• request information about consulting or mentoring;
• subscribe to email updates or educational material;
• respond to a survey, questionnaire or request for feedback;
• submit a correction, platform or editorial enquiry;
• purchase or register for a service, where available;
• interact with the website, cookies or analytics technologies;
• communicate through telephone, video call or another agreed channel.

We may also receive information from service providers, public business sources, professional contacts or referral partners where this is lawful and relevant to the communication or service.

You may browse general public content without identifying yourself. However, some information is required when you ask for a response or request a service.

4. How we use personal information

We may use personal information to:

• respond to questions, requests and professional enquiries;
• assess whether a consulting or mentoring engagement is appropriate;
• provide agreed services and manage client communications;
• operate, maintain and secure the website;
• understand website usage and improve content performance;
• administer email subscriptions and communication preferences;
• review editorial corrections and product information;
• manage invoices, records and administrative obligations;
• prevent spam, misuse, fraud and security incidents;
• comply with legal, regulatory or dispute-resolution requirements;
• protect our rights, users, systems and legitimate business interests.

5. Legal bases for processing

Where a legal basis is required under applicable data protection law, personal information may be processed on one or more of the following grounds:

• Consent: where you have voluntarily agreed to a specific use, such as receiving optional email updates.
• Contractual necessity: where processing is required to provide a service or take requested steps before entering an engagement.
• Legitimate interests: where reasonably necessary to operate, secure, analyse or improve the website and business without overriding your rights.
• Legal obligations: where records or information must be handled to comply with applicable law.
• Legal claims and protection: where processing is necessary to establish, exercise or defend legal rights.

Where processing relies on consent, you may withdraw that consent. Withdrawal does not affect processing that occurred lawfully before the withdrawal.

6. Cookies, analytics and similar technologies

The website may use cookies and similar technologies to maintain website functionality, remember preferences, improve security, measure traffic and understand how visitors interact with content.

These technologies may collect information such as:

• pages viewed and time spent on pages;
• referring websites and search sources;
• browser, device and operating-system information;
• approximate geographic region;
• website actions, errors and performance information.

You can manage cookies through your browser and any cookie controls made available on the website. Blocking certain cookies may affect website functionality.

Additional information is available in the separate Cookie Policy.

7. When information may be disclosed

We do not sell personal information. Personal information may be disclosed only where reasonably necessary to:

• website hosting, maintenance and security providers;
• email delivery and communication platforms;
• analytics and website performance providers;
• anti-spam, form processing and cybersecurity services;
• payment, accounting or administrative providers where relevant;
• professional advisers such as legal or accounting professionals;
• contractors assisting with an agreed service under appropriate confidentiality obligations;
• regulators, courts, law-enforcement bodies or government authorities when legally required;
• a successor or purchaser in connection with a legitimate business transfer, subject to appropriate safeguards.

Service providers are permitted to handle personal information only for the purposes relevant to the services they provide, subject to their own legal obligations and applicable agreements.

8. International data transfers

Some hosting, email, analytics, security or software providers may process or store information outside Australia.

Depending on the provider, information may be handled in countries including Australia, the United States, the United Kingdom, countries within the European Economic Area or other locations in which the provider operates.

Where required, reasonable contractual, organisational or technical measures are used to protect information transferred internationally. However, privacy laws and regulatory protections can vary between countries.

9. How long information is retained

Personal information is retained only for as long as reasonably necessary for the purpose for which it was collected, including:

• responding to and documenting enquiries;
• providing and administering agreed services;
• maintaining financial, contractual or business records;
• resolving complaints and disputes;
• meeting legal and regulatory obligations;
• maintaining website security and preventing misuse.

Retention periods differ according to the type of information and the applicable legal, contractual and operational requirements. Information that is no longer required may be deleted, anonymised or securely archived.

10. Data security

Reasonable administrative, technical and organisational safeguards are used to protect personal information from loss, misuse, interference, unauthorised access, alteration and disclosure.

Measures may include:

• website encryption and secure connections;
• controlled access to administrative systems;
• software and security updates;
• anti-spam and threat-monitoring tools;
• service-provider access restrictions;
• backup and recovery procedures.

No website, email system or internet transmission can be guaranteed to be completely secure. You are responsible for taking reasonable care when choosing what information to send electronically.

11. Access, correction and other privacy rights

Depending on your location and applicable law, you may have rights relating to your personal information.

Australian privacy requests

You may request:

• access to personal information held about you;
• correction of information that is inaccurate, incomplete or outdated;
• information about how your personal information has been handled;
• consideration of a privacy complaint.

European Economic Area and United Kingdom

Where applicable, you may also have the right to:

• request erasure of personal data;
• restrict certain processing;
• object to processing based on legitimate interests;
• object to direct marketing;
• receive certain data in a portable format;
• withdraw consent;
• complain to an applicable data protection authority.

Some rights are subject to legal exceptions. We may request reasonable evidence of identity before responding to a request.

Requests can be sent to [email protected].

12. Email and marketing communications

We may send educational updates, website content or relevant service information where you have requested it or where otherwise permitted by applicable law.

You may unsubscribe through the link contained in an email or by contacting us directly. Administrative messages concerning an existing enquiry or service may still be sent when necessary.

We do not guarantee that every email sent over the internet will be secure, uninterrupted or received by the intended recipient.

13. Children’s privacy

The website and its business, marketing and investment education content are intended for a general adult audience and are not directed to children under 16.

We do not knowingly seek to collect personal information from children. A parent or guardian who believes a child has provided personal information may contact us to request its review and deletion.

14. External websites and embedded services

The website may link to or embed content from third-party websites, social platforms, software providers, investment platforms or other external services.

Those third parties operate under their own privacy policies, cookies and data practices. Phil Adair Training is not responsible for the privacy or security practices of independent external websites.

Review the relevant provider’s privacy information before supplying personal information or creating an account.

15. Questions and privacy complaints

Contact us if you have a question, want to exercise a privacy right or believe personal information has been handled incorrectly.

Please provide enough detail to identify the relevant interaction and explain the resolution you are requesting. Do not include unnecessary sensitive information.

If an Australian privacy concern cannot be resolved directly, you may be entitled to contact the Office of the Australian Information Commissioner or another applicable regulator.

16. Changes to this Privacy Policy

This Privacy Policy may be updated to reflect changes to website functions, business practices, service providers or applicable law.

The latest version will be published on this page with a revised “Last updated” date. Material changes may also be communicated through the website or another appropriate channel.

Continued use of the website after an update means that the revised policy will apply to subsequent interactions, subject to any consent requirements imposed by law.