EDUCHIRO PRIVACY POLICY

1. INTRODUCTION

Adjustment Productions Pty Ltd trading as Educhiro ("Educhiro", "we", "us" or "our") owns and operates the website www.educhiro.com and provides digital chiropractic patient education videos and related subscription services to chiropractic businesses worldwide.

This Privacy Policy applies to Educhiro and, where relevant, its subsidiaries and related entities when handling personal information in connection with Educhiro's services.

Educhiro respects the privacy of individuals who visit our website, subscribe to our services, communicate with us or otherwise interact with our business.

We are committed to protecting personal information and handling it responsibly, securely and transparently.

As an Australian business, we conduct our operations in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs"), to the extent applicable.

We also comply with other relevant international privacy and data protection laws where they apply to our activities.

This Privacy Policy explains:

What personal information we collect.
How and why we collect and use personal information.
How subscriber accounts and website access are monitored.
How streaming activity and digital watermarking information are handled.
How personal information may be used to protect Educhiro's intellectual property.
How information is disclosed and processed internationally.
How long information may be retained.
How individuals may access, correct or request deletion of personal information.
How privacy enquiries and complaints are handled.

This Privacy Policy should be read together with Educhiro's Terms and Conditions.

By using our website or services, individuals acknowledge that they have been provided with access to this Privacy Policy. Where consent is required by applicable law, Educhiro will obtain that consent separately.

2. WHAT IS PERSONAL INFORMATION?

Under Australian privacy law, personal information generally means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether it is recorded in a material form or not.

Personal information may include names, contact details, account information and technical identifiers that can reasonably identify an individual.

2.1 Sensitive Information

Sensitive information is a category of personal information defined under the Privacy Act.

It may include information concerning:

a. Racial or ethnic origin.

b. Political opinions or political association membership.

c. Religious beliefs or affiliations.

d. Philosophical beliefs.

e. Membership of professional or trade associations.

f. Trade union membership.

g. Sexual orientation or practices.

h. Criminal records.

i. Health information.

j. Genetic information.

k. Certain biometric information.

Educhiro does not ordinarily require sensitive personal information to provide its subscription services and does not intentionally collect patient medical histories or clinical records through its standard subscription process.

Where sensitive information is collected, we will do so only where permitted by applicable law, including obtaining consent where required.

If sensitive information is received inadvertently and is not required for a lawful purpose, we will take reasonable steps to securely delete or de-identify it, subject to applicable legal obligations.

3. WHO THIS PRIVACY POLICY APPLIES TO

This Privacy Policy applies to personal information collected from or about:

a. Visitors to the Educhiro website.

b. Individuals registering for Educhiro subscriptions.

c. Chiropractors and authorised practice personnel.

d. Business owners and account administrators.

e. Individuals contacting Educhiro by telephone, email, SMS or other communication methods.

f. Affiliate participants and prospective business partners.

g. Individuals interacting with Educhiro's authorised streaming or video-viewing services.

h. Other individuals whose personal information is lawfully collected in connection with Educhiro's operations.

Our subscription registration services are intended for individuals aged 18 years or older.

4. PERSONAL INFORMATION WE COLLECT

Depending on the nature of an individual's relationship with Educhiro, we may collect the following information.

4.1 Personal and Business Contact Information

This may include:

a. Full name.

b. Email address.

c. Telephone and mobile telephone numbers.

d. Postal, business and billing addresses.

e. Chiropractic business name.

f. Business logos and branding materials.

g. Professional qualifications, accreditations and registration details.

h. Clinic locations and associated business information.

i. Other information reasonably necessary to provide our services.

4.2 Account Information

We may collect:

a. Subscriber account identifiers.

b. Login credentials and authentication information.

c. Account status and subscription history.

d. Registered website domain or approved subdomain.

e. Authorised business and clinic information.

f. Account administration and support records.

Passwords should be stored using appropriate secure authentication methods, such as industry-standard password hashing, rather than retained in readable form.

4.3 Payment Information

We may collect information necessary to administer subscriptions, including:

a. Billing details.

b. Subscription plans and payment history.

c. Transaction identifiers.

d. Invoice records.

e. Payment status.

f. Cancellation and refund records.

g. Bank account information where required for an authorised payment or refund arrangement.

Payment processing may be performed by third-party payment providers, including Stripe where applicable.

Payment providers may collect and process payment card information in accordance with their own privacy notices and applicable contractual arrangements.

Educhiro does not ordinarily require access to complete payment card numbers where payments are processed through an appropriately configured payment provider.

4.4 Information Required or Authorised by Law

We may collect information reasonably necessary to comply with legal, taxation, accounting, regulatory or other lawful obligations.

4.5 Accuracy of Information

Subscribers are responsible for providing accurate account information and notifying Educhiro when their details change.

Subscribers should update their account details or contact Educhiro when business names, addresses, authorised website domains or other relevant information changes.

Educhiro takes reasonable steps to maintain accurate, complete and up-to-date personal information.

5. HOW WE COLLECT PERSONAL INFORMATION

We may collect information:

a. Directly through website registration forms.

b. Through subscription and account management activities.

c. Through telephone, email, SMS and other communications.

d. Through payment and billing arrangements.

e. Automatically through website and streaming technologies.

f. Through cookies and similar technologies.

g. From authorised contractors and service providers.

h. From affiliates, referral partners or other business contacts.

i. From publicly available sources where collection is lawful and appropriate.

j. From third parties where the information is relevant to our services and may lawfully be collected.

5.1 Information Obtained from Third Parties

Where personal information is obtained from third parties, we will assess whether the collection is permitted by applicable law and whether appropriate privacy notices or other safeguards are required.

Where information has been obtained in circumstances that do not permit us to retain it, we will take appropriate steps to delete or de-identify it, subject to applicable legal obligations.

5.2 Publicly Available Information

Educhiro may collect relevant professional or business contact information from publicly available sources where lawful.

We will not assume that information may be used for any purpose merely because it is publicly accessible.

We will consider applicable privacy, direct marketing and other legal requirements before collecting or using such information.

5.3 Combining Information

Where information from different sources is combined, Educhiro will take reasonable steps to ensure the collection and use are lawful, relevant and appropriate.

Where practicable and suitable, information may be aggregated or de-identified to reduce privacy risks.

De-identification will be assessed in light of the risk that an individual could reasonably be re-identified.

5.4 Anonymous or Pseudonymous Interactions

Where lawful and practicable, individuals may interact with Educhiro anonymously or using a pseudonym.

However, certain services, including paid subscriptions, account administration and billing, require information sufficient to identify the subscribing business and relevant account contacts.

If necessary information is not provided, we may be unable to provide some or all requested services.

6. MANDATORY REGISTRATION ACCEPTANCE

New Subscribers must actively accept Educhiro's Terms and Conditions during registration.

The registration process requires an unchecked-by-default acceptance checkbox linked to the current Terms and Conditions.

Registration cannot be completed unless the Subscriber selects the checkbox.

Educhiro maintains an electronic record of acceptance, which may include:

a. Subscriber or business account identifier.

b. The version of the Terms accepted.

c. Date and time of acceptance, recorded in Coordinated Universal Time (UTC).

d. The recorded acceptance action.

e. Relevant technical information lawfully collected during registration.

Acceptance records may be used for:

Subscription administration.
Contractual recordkeeping.
Verification of accepted licence conditions.
Resolution of billing or contractual disputes.
Establishment, exercise or defence of legal claims.

Acceptance of the Terms and Conditions does not automatically constitute consent to optional marketing communications.

7. WEBSITE AND TECHNICAL INFORMATION

When individuals access Educhiro's website or services, we may collect technical information including:

a. IP addresses.

b. Date and time of access.

c. Browser type and version.

d. Device and operating system information.

e. Pages visited and website interactions.

f. Session identifiers.

g. Referring website information.

h. Technical errors and diagnostic information.

i. Security and authentication events.

This information may be used to operate the website, assess performance, identify technical issues, improve services and protect against unauthorised activity.

Where third-party analytics or tracking technologies are used, Educhiro will comply with applicable notice and consent requirements.

8. COOKIES AND SIMILAR TECHNOLOGIES

Educhiro may use cookies and similar technologies to support website functionality and user experience.

These technologies may be used for:

a. Account authentication.

b. Session management.

c. Website navigation.

d. Remembering preferences.

e. Security and fraud prevention.

f. Website performance measurement.

g. Analytics and marketing, where implemented and legally permitted.

Most browsers allow users to control or reject cookies.

Disabling essential cookies may prevent certain website functions, including account login, subscription management or payment processing, from operating correctly.

Where applicable law requires consent for non-essential cookies or similar technologies, Educhiro will obtain that consent before activating them.

A separate cookie notice or preference-management facility may be provided where required.

9. STREAMING ACTIVITY AND VIDEO PLAYBACK MONITORING

Educhiro monitors and records technical information associated with access to and playback of its copyrighted educational videos.

Information collected may include:

a. Subscriber account identifiers.

b. Video and streaming session identifiers.

c. Playback dates, times and activity.

d. IP addresses and relevant device information.

e. Authentication and account access records.

f. Registered website domains and embedding requests.

g. Playback errors and technical events.

h. Security alerts and unusual access patterns.

i. Digital watermark and content-identification information.

This information is used to:

a. Deliver and maintain video services.

b. Verify authorised subscription access.

c. Maintain streaming quality and troubleshoot technical issues.

d. Enforce registered-domain licensing restrictions.

e. Detect suspected account sharing or unauthorised access.

f. Investigate suspected copying, recording or redistribution.

g. Protect Educhiro's copyrighted educational materials.

h. Establish, exercise or defend legal claims where necessary.

Educhiro may retain streaming logs, account access records and related technical information for as long as reasonably necessary to monitor authorised use, investigate suspected copyright infringement, protect its intellectual property and establish, exercise or defend legal claims.

Retention periods will take into account the nature of the information, its relevance to ongoing copyright protection, the possibility of delayed discovery of unauthorised distribution, applicable legal limitation periods and relevant privacy and data protection requirements.

Where copyright infringement is suspected, identified or subject to investigation or legal proceedings, relevant records may be preserved for an extended period where reasonably necessary and legally permitted.

Educhiro will periodically review retained information and securely delete or de-identify personal information when it is no longer reasonably required for a lawful purpose, subject to applicable legal obligations.

Streaming records alone do not establish that an individual has committed copyright infringement.

10. DIGITAL WATERMARKING AND CONTENT IDENTIFICATION

Educhiro uses digital watermarking technology as an established component of its video content-protection system.

Digital watermarking is used to associate protected video content with relevant subscriber, licensing or identification information.

Watermarking assists Educhiro in:

a. Identifying the potential source of unauthorised video copies.

b. Investigating suspected recording, copying or redistribution.

c. Detecting potential breaches of subscription licensing conditions.

d. Protecting copyrighted educational materials.

e. Supporting lawful copyright enforcement and legal proceedings.

Digital watermark identifiers and associated technical records form part of Educhiro's content-protection and security records.

These records may be retained for as long as reasonably necessary to protect Educhiro's intellectual property and investigate suspected infringement, subject to applicable privacy and data protection laws.

Access to identifiable watermark information will be restricted to authorised personnel and service providers with a legitimate need for access.

A watermark match does not, by itself, conclusively establish that a particular individual personally committed an infringement.

11. WEBSITE DOMAIN VERIFICATION

Educhiro subscriptions permit video embedding on one authorised website domain, subject to the Terms and Conditions.

To administer this restriction, Educhiro may collect and maintain information concerning:

a. The registered domain or approved subdomain.

b. The subscribing business associated with that domain.

c. Website embedding requests.

d. Domain verification events.

e. Relevant technical access records.

f. Suspected attempts to use videos on unauthorised domains.

This information may be used to verify licensing arrangements, prevent unauthorised embedding and maintain the integrity of Educhiro's streaming services.

One subscription may cover multiple physical clinic locations operated by the same subscribing legal entity, as described in the Terms and Conditions.

12. HOW WE USE PERSONAL INFORMATION

Educhiro may use personal information for the following purposes:

a. Identification and authentication.

b. Subscription registration and account management.

c. Accounting, invoicing, billing and payment administration.

d. Providing, maintaining and improving our services.

e. Website and streaming performance evaluation.

f. Providing technical and customer support.

g. Contacting Subscribers about their accounts or services.

h. Developing new products, features and services.

i. Conducting research and analysing service performance.

j. Maintaining relationships with affiliate and referral partners.

k. Providing or arranging relevant verification services.

l. Protecting Educhiro and users of its website.

m. Detecting fraud, security incidents and unauthorised access.

n. Investigating suspected copyright infringement.

o. Protecting Educhiro's intellectual property.

p. Enforcing contractual rights and payment obligations.

q. Complying with lawful requests from courts, regulators or competent authorities.

r. Establishing, exercising or defending legal claims.

s. Conducting marketing activities where permitted by applicable law.

t. Other purposes authorised or required by applicable law.

Where a proposed use is materially different from the purpose for which information was collected, Educhiro will assess whether further notice, consent or another lawful basis is required.

13. COPYRIGHT INFRINGEMENT AND SECURITY INVESTIGATIONS

Educhiro may investigate suspected unauthorised access, copying, recording, distribution, resale or commercial playback of its copyrighted videos.

Where reasonably necessary and legally permitted, investigations may involve reviewing:

a. Subscription and account records.

b. Registration acceptance records.

c. Streaming and playback logs.

d. Authentication and security records.

e. Registered-domain information.

f. Digital watermark identifiers.

g. Relevant technical evidence.

h. Publicly available evidence of suspected infringement.

i. Other information lawfully obtained for the investigation.

Information may be preserved where reasonably necessary to investigate suspected infringement or to establish, exercise or defend legal claims.

Where legally permitted, relevant evidence may be disclosed to professional advisers, legal representatives, courts, competent authorities or other appropriate recipients.

Investigations will be conducted subject to applicable privacy and data protection laws.

Educhiro will not treat suspicious technical activity alone as conclusive evidence of wrongdoing.

14. DISCLOSURE OF PERSONAL INFORMATION

Educhiro does not sell, rent or trade personal information to third parties.

We may disclose personal information where reasonably necessary and legally permitted, including to:

a. Subsidiaries and related entities involved in Educhiro operations.

b. Contractors engaged to provide services on our behalf.

c. Website hosting and cloud infrastructure providers.

d. Video streaming and content delivery providers.

e. Payment processors.

f. Authentication, security and technical support providers.

g. Email and communications providers.

h. Accountants, auditors, lawyers and other professional advisers.

i. Affiliate or verification service providers where relevant and lawful.

j. Courts, tribunals, regulators and competent authorities.

k. Other recipients where disclosure is authorised by the individual or permitted by applicable law.

14.1 Contractors and Service Providers

Where personal information is provided to contractors or service providers acting on our behalf, we will implement appropriate contractual and organisational safeguards.

These may include obligations concerning confidentiality, security, authorised processing and restrictions on further disclosure.

14.2 Business Sale or Restructuring

Personal information may be disclosed in connection with a proposed or completed sale, merger, acquisition, restructuring or transfer of some or all of Educhiro's business or assets, where legally permitted and subject to appropriate safeguards.

14.3 Legal and Safety Disclosures

Information may be disclosed where authorised or required by law, including where reasonably necessary to:

a. Respond to lawful court or regulatory requirements.

b. Investigate suspected unlawful activity.

c. Protect against serious threats to life, health or safety.

d. Protect the security of our systems.

e. Establish, exercise or defend legal claims.

f. Enforce intellectual property rights.

Any disclosure will remain subject to applicable legal requirements.

15. INTERNATIONAL DATA PROCESSING AND TRANSFERS

Educhiro is an Australian business providing subscription-based digital educational services worldwide.

Our services are accessible internationally, and personal information may be collected, transmitted, stored, accessed or otherwise processed in different countries depending on the location of Subscribers, authorised users, service providers and relevant technology infrastructure.

International processing may involve:

a. Website hosting and cloud infrastructure.

b. Video streaming and content delivery networks.

c. Authentication and account management systems.

d. Payment processing providers.

e. Email and communications platforms.

f. Security monitoring and copyright-protection systems.

g. Technical support and authorised service providers.

h. Lawful international investigations and legal proceedings.

The worldwide availability of Educhiro's services does not mean that personal information will necessarily be stored or accessed in every country.

Where international transfers or overseas disclosures occur, Educhiro will comply with applicable privacy and data protection requirements.

Appropriate safeguards may include contractual confidentiality and security obligations, lawful international transfer mechanisms, Standard Contractual Clauses where required, and other protections appropriate to the circumstances.

Where Australian Privacy Principle 8 applies, Educhiro will address its requirements concerning overseas disclosure of personal information.

Where the EU GDPR or UK GDPR applies, Educhiro will comply with the applicable international transfer requirements.

Information about relevant service providers, processing locations and transfer safeguards will be provided where required by law.

16. HOW WE STORE AND PROTECT PERSONAL INFORMATION

Educhiro takes reasonable technical and organisational steps to protect personal information against:

a. Misuse.

b. Interference.

c. Loss.

d. Unauthorised access.

e. Unauthorised modification.

f. Unauthorised disclosure.

Depending on the systems involved, safeguards may include:

Access control procedures.
Secure authentication.
Network security and firewalls.
Encryption in transit and, where appropriate, at rest.
Restricted administrative access.
Physical security controls.
Security monitoring.
Appropriate service-provider security arrangements.

No internet-based service can guarantee absolute security.

Educhiro will take reasonable steps to maintain appropriate safeguards and respond to security incidents.

Where a personal information breach occurs, we will assess whether notification is required under applicable law, including Australia's Notifiable Data Breaches scheme where applicable.

Individuals should notify Educhiro promptly if they become aware of suspected unauthorised access to their accounts.

17. ACCOUNT PASSWORD SECURITY

Subscribers are responsible for taking reasonable precautions to protect their account credentials.

We recommend that Subscribers:

a. Use strong, unique passwords.

b. Avoid sharing passwords with unauthorised individuals.

c. Store passwords securely, preferably using a reputable password manager.

d. Protect devices used to access their accounts.

e. Notify Educhiro promptly if they suspect unauthorised access.

Credentials may be used only by authorised personnel or service providers acting on behalf of the subscribing business, subject to the Terms and Conditions.

Educhiro will take reasonable measures to protect authentication information within systems under its control.

18. DATA RETENTION

Educhiro retains personal information for periods reasonably necessary to provide its services, administer subscriptions, maintain security, protect its intellectual property, comply with legal obligations and establish, exercise or defend legal claims.

Retention periods may differ depending on the nature of the information, its purpose and applicable legal requirements.

18.1 Subscription and Account Records

Account and subscription information may be retained while a subscription is active and for an appropriate period afterwards to satisfy contractual, accounting, taxation, legal and operational requirements.

18.2 Terms Acceptance Records

Electronic acceptance records may be retained for periods reasonably necessary to establish the applicable contractual terms and resolve or defend related claims.

18.3 Streaming, Playback and Security Logs

Educhiro may retain streaming logs, account access records, authentication information and related technical records for as long as reasonably necessary to monitor authorised use, investigate suspected copyright infringement, protect its intellectual property and establish, exercise or defend legal claims.

Retention periods will take into account:

a. The nature and sensitivity of the information.

b. Its relevance to ongoing copyright protection.

c. The possibility of delayed discovery of unauthorised distribution.

d. Applicable legal limitation periods.

e. Relevant privacy and data protection requirements.

f. The need to preserve evidence for existing or reasonably anticipated legal proceedings.

18.4 Digital Watermark Records

Digital watermark identifiers and associated content-protection information may be retained for as long as reasonably necessary to identify suspected unauthorised copies, investigate infringement and protect Educhiro's intellectual property, subject to applicable law.

18.5 Domain Verification Records

Registered-domain information and relevant embedding and access records may be retained for licence administration, security and copyright-protection purposes.

18.6 Cancellation Records

Subscription cancellation requests, including records relevant to the contractual 60-day written notice period, may be retained for appropriate contractual, accounting and legal purposes.

18.7 Copyright Infringement and Legal Evidence

Where infringement, fraud, unauthorised distribution or a legal dispute is suspected, identified or reasonably anticipated, Educhiro may preserve relevant records and evidence for an extended period where reasonably necessary and legally permitted.

18.8 Periodic Review and Deletion

Educhiro will periodically review retained personal information and take reasonable steps to securely delete, destroy or de-identify information when it is no longer reasonably required for a lawful purpose, subject to applicable legal obligations.

Where practicable, information no longer required in identifiable form may be de-identified while retaining non-identifying technical information for legitimate security, statistical or operational purposes.

Educhiro does not apply an unconditional indefinite retention period to all identifiable personal information.

19. PATIENT INFORMATION AND HEALTH DATA

Educhiro provides educational video services to chiropractic businesses.

Our standard subscription services are not intended to require the collection of individual patient medical histories, diagnoses, treatment records or other sensitive clinical information.

Subscribers should not provide patient health information through general Educhiro support or administrative systems unless specifically authorised and supported by appropriate arrangements.

Where Educhiro processes identifiable information relating to patients or video viewers, the relevant responsibilities of Educhiro and the subscribing chiropractic business will depend on the functionality involved and applicable law.

Subscribers remain responsible for providing appropriate privacy information to their patients where required.

Where Educhiro processes personal information on behalf of a chiropractic business, additional data processing terms may be required.

20. DIRECT MARKETING

Educhiro may communicate with Subscribers, prospective customers and business contacts about:

a. Product updates.

b. Educational resources.

c. New features.

d. Subscription offers.

e. Promotional activities.

f. Relevant services and business developments.

Marketing communications will be sent only where permitted by applicable law.

Where consent is required, Educhiro will obtain appropriate consent.

Recipients may opt out of marketing communications using an available unsubscribe facility or by contacting info@educhiro.com.

Opting out of marketing does not prevent Educhiro from sending necessary billing, security, account or contractual communications.

Sensitive information will not be used for direct marketing without any consent or other authorisation required by applicable law.

21. ACCESS TO PERSONAL INFORMATION

Individuals may request access to personal information held about them.

Requests should be directed to:

info@educhiro.com

Before providing access, Educhiro may require reasonable evidence of identity.

We will respond in accordance with applicable privacy laws.

Access will ordinarily be provided without charge where required by law. Where permitted, a reasonable fee may apply for providing access, but not for making a request.

Access may be refused or limited where an applicable legal exception exists.

Where a request is refused, Educhiro will provide an explanation and information about available complaint mechanisms where required by law.

22. CORRECTION OF PERSONAL INFORMATION

Educhiro takes reasonable steps to ensure that personal information it collects, uses or discloses is accurate, complete, relevant and up to date.

Individuals may request correction of information that is inaccurate, incomplete, irrelevant, misleading or out of date.

Requests may be submitted to info@educhiro.com.

Where appropriate, Educhiro will correct the information or take other steps required by applicable law.

If a correction request is refused, Educhiro will provide the reasons and information about applicable complaint mechanisms where required by law.

23. DELETION, RESTRICTION AND OTHER PRIVACY RIGHTS

Depending on applicable law, individuals may have rights to:

a. Request deletion of personal information.

b. Request restriction of processing.

c. Object to certain processing activities.

d. Withdraw consent where processing is based on consent.

e. Request data portability.

f. Request information about processing.

g. Lodge a complaint with a relevant privacy authority.

These rights may be subject to lawful exceptions, including requirements to retain information for legal obligations or the establishment, exercise or defence of legal claims.

Educhiro will respond to requests within applicable legal timeframes.

24. GDPR AND INTERNATIONAL DATA PROTECTION

Where Educhiro's activities are subject to the European Union General Data Protection Regulation ("EU GDPR") or United Kingdom General Data Protection Regulation ("UK GDPR"), we will comply with the applicable requirements.

24.1 Data Controller and Data Processor Responsibilities

Educhiro may act as a data controller for personal information it collects and uses for its own purposes, including:

a. Subscriber registration.

b. Billing and subscription management.

c. Customer support.

d. Website administration.

e. Account security.

f. Copyright protection and legal claims.

In certain circumstances, Educhiro may act as a data processor when processing personal information on behalf of a subscribing chiropractic business under that business's documented instructions.

The applicable role depends on the particular processing activity and legal arrangements.

24.2 Lawful Bases

Where GDPR requirements apply, Educhiro will identify an appropriate lawful basis for processing personal information.

Depending on the circumstances, this may include:

a. Performance of a contract with an individual.

b. Compliance with legal obligations.

c. Legitimate interests, subject to applicable balancing requirements.

d. Consent.

e. Other lawful bases available under applicable law.

For example, account security and proportionate copyright-protection activities may be assessed under legitimate interests where applicable, while processing necessary to perform a contract with an individual may rely on contractual necessity.

24.3 Data Processor Obligations

Where Educhiro acts as a processor under applicable GDPR requirements, appropriate contractual arrangements will address matters including:

a. Processing on documented instructions.

b. Confidentiality obligations.

c. Appropriate technical and organisational security measures.

d. Conditions for engaging subprocessors.

e. Assistance with applicable individual rights requests.

f. Assistance with security incidents and legally required notifications.

g. Assistance with applicable impact assessments and regulatory consultations.

h. Return or deletion of relevant personal data at the end of processing, subject to legal requirements.

i. Records and information necessary to demonstrate compliance.

j. Applicable audit and verification arrangements.

24.4 Personal Data Breaches

Where Educhiro acts as a processor, it will notify the relevant controller without undue delay after becoming aware of a personal data breach, in accordance with applicable contractual and legal requirements.

Where Educhiro acts as a controller, it will assess and meet its own applicable breach notification obligations.

24.5 EU and UK Representatives

Where legally required, Educhiro will appoint an appropriate representative in the European Union or United Kingdom and provide the relevant contact details.

24.6 International Transfers

Where GDPR applies, personal data transfers outside the relevant jurisdiction will be conducted using a lawful transfer mechanism and any additional safeguards required by applicable law.

24.7 Individual Rights

Where GDPR applies, individuals may exercise applicable rights relating to access, correction, erasure, restriction, objection, portability and withdrawal of consent.

Requests will be handled within the timeframes and subject to the conditions established by applicable law.

25. CHILDREN'S PRIVACY

Educhiro's subscription registration services are intended for adults acting on behalf of chiropractic businesses.

Individuals under the age of 18 must not register for an Educhiro subscription.

Educhiro does not intentionally solicit personal information from children through its subscription registration process.

Where personal information relating to a child is received in circumstances requiring additional authorisation or safeguards, Educhiro will take appropriate action under applicable law.

This restriction on subscription registration does not, by itself, prohibit patients under 18 from viewing educational material lawfully made available through their chiropractic practice.

26. THIRD-PARTY WEBSITES AND SERVICES

Educhiro's website and services may contain links to or integrations with third-party websites and technologies.

These third parties may have their own privacy policies and data processing practices.

Individuals should review relevant third-party privacy notices.

Educhiro is not responsible for independent activities of third parties except to the extent responsibility arises under applicable law or contractual arrangements.

27. CHANGES TO THIS PRIVACY POLICY

Educhiro may update this Privacy Policy to reflect changes in:

a. Applicable laws and regulations.

b. Business operations.

c. Website and streaming technology.

d. Account security systems.

e. Digital watermarking and content protection.

f. Data collection and retention practices.

g. Service-provider arrangements.

h. Privacy and data protection procedures.

The updated policy will be published on the Educhiro website with its effective or last-updated date.

Where material changes require additional notice or consent, Educhiro will provide that notice or obtain consent as required by applicable law.

28. PRIVACY COMPLAINTS

Individuals who believe their personal information has been handled improperly may submit a written complaint to Educhiro.

Complaints should include sufficient information to allow us to understand and investigate the concern.

Complaints may be sent to:

info@educhiro.com

Educhiro will review privacy complaints and endeavour to respond within a reasonable period, usually within 30 days, subject to any shorter timeframe required by applicable law.

Where a complaint cannot be resolved directly, individuals may have the right to contact a relevant privacy regulator.

In Australia, this may include the Office of the Australian Information Commissioner (OAIC).

Individuals in other jurisdictions may also have the right to lodge complaints with their relevant data protection authority.

29. CONTACT INFORMATION

For questions about this Privacy Policy, access requests, correction requests, complaints or other privacy enquiries, contact:

Adjustment Productions Pty Ltd trading as Educhiro

Address: Suite 1, 5 Church Lane, Emerald, Queensland 4720, Australia

Website: https://www.educhiro.com

Email: info@educhiro.com

Telephone: +61 (0)409629628

Effective Date: 8th November 2008

END OF PRIVACY POLICY