Clearwise – Privacy Policy

This Privacy Policy explains how Deleonas Pty Ltd (trading as Clearwise Training, we, us, our) collects, uses, discloses and protects personal information in connection with the Clearwise website, training platform, learning management system (LMS), courses, videos, downloadable resources and related services (together, the Services).

This policy is designed to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

By using the Services, you consent to the handling of your personal information as described in this Privacy Policy.

1. Types of Personal Information We Collect

We may collect personal information that is reasonably necessary to provide the Services, including:

Identity and Contact Information

• name
• email address
• phone number
• employer or organisation name
• job title or role

Account Information

• username and password
• account preferences
• user profile information
• organisation affiliation

Training and Usage Data

• course enrolments
• course progress and completion records
• quiz responses and assessment results
• CPD tracking information
• timestamps of activity within the LMS
• certificates or completion records

Technical and Device Information

• IP address
• browser type
• device type
• operating system
• referring URLs
• pages viewed
• session duration
• approximate location (based on IP)

Payment Information

Payments are processed via third-party payment providers (e.g. Stripe). We do not store full credit card details.

We may receive limited payment-related information such as:

• payment status
• transaction ID
• billing name
• billing email
• subscription status

Communications

• enquiries submitted via contact forms
• support requests
• feedback
• survey responses
• communications relating to course participation

2. How We Collect Personal Information

We may collect personal information when you:

• create an account
• purchase a course or subscription
• enrol in training modules
• complete quizzes or assessments
• download materials
• contact us via forms or email
• interact with the website or LMS
• subscribe to updates or newsletters
• participate in surveys or feedback requests

We may also collect technical information automatically through cookies and analytics tools.

Where reasonably practicable, we collect personal information directly from you.

3. Why We Collect Personal Information

We collect and use personal information for purposes including:

Providing the Services

• creating and managing user accounts
• delivering training modules and resources
• tracking course progress and completion
• administering quizzes and assessments
• providing certificates or CPD records
• processing payments
• managing subscriptions

Operating and Improving the Platform

• maintaining system security
• troubleshooting technical issues
• analysing platform usage and performance
• improving course content and user experience
• developing new features and training materials

Communication

• responding to enquiries and support requests
• providing service updates
• notifying users of changes to courses or Terms
• providing important administrative messages

Compliance and Risk Management

• maintaining records of course participation
• responding to legal or regulatory obligations
• enforcing our Terms of Use
• preventing misuse of the platform

We do not sell personal information.

4. Legal Basis for Processing

We collect and use personal information where reasonably necessary for our legitimate business purposes, including providing training services and operating the LMS.

Where required, we rely on:

• your consent
• performance of a contract
• compliance with legal obligations
• legitimate interests in operating and improving the Services

5. Disclosure of Personal Information

We may disclose personal information to service providers that support operation of the Services, including:

Technology Providers

• LMS hosting providers
• cloud hosting providers
• analytics providers
• email delivery providers
• authentication providers

Payment Processors

• payment processing providers (such as Stripe)

Video and Content Infrastructure

• video hosting providers (such as Mux)
• content delivery networks

Platform Infrastructure

• website hosting providers (such as Webflow)
• database hosting providers

These providers may store data in Australia or overseas.

We take reasonable steps to ensure service providers handle personal information appropriately.

We may also disclose information:

• where required by law
• to regulators or authorities
• to enforce our Terms
• to protect rights, safety or property

6. Overseas Disclosure

Some service providers may store or process personal information outside Australia, including in:

• United States
• European Union
• other jurisdictions where our technology providers operate infrastructure

We take reasonable steps to ensure overseas recipients handle personal information consistently with Australian privacy standards.

7. Cookies and Analytics

We may use cookies, pixels and similar technologies to:

• maintain login sessions
• remember user preferences
• analyse platform usage
• improve website functionality
• monitor performance and reliability

Cookies may collect information such as:

• IP address
• browser information
• pages visited
• time spent on pages
• referring websites

You can adjust browser settings to disable cookies, although some parts of the Services may not function properly.

8. Data Security

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure.

Security measures may include:

• encrypted connections (HTTPS)
• secure authentication systems
• restricted administrative access
• monitoring of platform activity
• secure hosting infrastructure

No method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

9. Data Retention

We retain personal information only for as long as reasonably necessary to:

• provide the Services
• maintain training records
• comply with legal obligations
• resolve disputes
• enforce agreements

We may retain course completion records after an account becomes inactive for compliance and record-keeping purposes.

We may de-identify or delete personal information where it is no longer required.

10. Access and Correction

You may request access to personal information we hold about you and request corrections if the information is inaccurate.

Requests may be made via our contact form.

We will respond within a reasonable period.

We may require verification of identity before providing access.

11. Marketing Communications

We may send administrative communications relating to:

• course enrolment
• account activity
• important updates
• platform changes
• service notices

We may send optional marketing communications where permitted by law.

You may opt out of marketing communications at any time using unsubscribe links or by contacting us.

Service-related communications will still be sent where necessary.

12. Third-Party Services

The Services may integrate with third-party providers.

These providers may collect information in accordance with their own privacy policies.

Examples may include:

• payment providers
• video hosting services
• analytics providers
• cloud hosting providers

We are not responsible for the privacy practices of third-party providers.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Changes take effect when published on our website.

Where changes are material, we may notify users via email or platform notification.

14. Complaints

If you believe we have breached applicable privacy laws, you may contact us using our contact form.

We will investigate and respond within a reasonable period.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).

15. Contact

For privacy-related questions, access requests or complaints, please contact us via the contact form on our website.