Privacy Policy

Purpose	Example	Legal basis
Providing services	Accounts, memberships, courses, counselling, coaching, bookings, support tools	Performance of a contract, or steps at your request before entering a contract
Processing payments and records	Billing, receipts, tax, accounting	Contract and legal obligation
Responding to enquiries	Contact forms, support tickets, pre-sale questions	Legitimate interests and/or steps at your request before contract
Marketing	Newsletters, offers, updates	Consent where required, and legitimate interests where lawful
Analytics and optional cookies	Website performance, usage trends	Consent where required
Personalisation	Content suggestions, member experience	Contract, legitimate interests, and consent where required
Sensitive information	Support-related, disability, counselling, or wellbeing information	Explicit consent, contract for requested services, or another lawful basis permitted by law
Security and fraud prevention	Monitoring, abuse prevention, incident response	Legitimate interests and legal obligation
Legal compliance	Court orders, regulator requests, tax obligations	Legal obligation
Service improvement and de-identified analytics	Product development, user experience improvements	Legitimate interests

 

We do not use your data for automated decision-making that produces legal, clinical, financial, employment, or similarly significant effects without meaningful human involvement.

6. AI-Supported Tools

Neuovara may offer Agenic AI Support Tools or other AI-supported features.

6.1 How AI tools may be used

AI features may be used to:

• provide support prompts or general guidance
• improve user navigation or experience
• suggest resources or content
• assist with summaries, drafting, or information support
• support members behind subscription or membership access controls

6.2 Human review

AI outputs may be reviewed by authorised human staff, contractors, counsellors, coaches, moderators, or support personnel where needed for:

• quality assurance
• safety
• support delivery
• troubleshooting
• service improvement

6.3 No significant automated decisions

Our AI tools are intended to provide guidance and support only. They are not intended to make legal, clinical, financial, or similarly significant decisions about you.

6.4 Personalisation and profiling

Where AI tools involve personalisation, we will provide choices where required by law. You may request to opt out of certain AI personalisation or profiling features where available.

6.5 Do not enter crisis or highly sensitive clinical information

You should not enter emergency, crisis, or highly sensitive clinical information into AI tools unless we clearly state that the relevant tool is designed and approved for that purpose.

If you are in crisis or need urgent support, do not rely on AI tools alone.

6.6 Third-party AI providers

We may use third-party AI providers, including OpenAI / ChatGPT or similar providers.

Some prompts, uploads, or AI interaction logs may be processed by those providers. Depending on the settings of the relevant tool, some of that information may also be retained or used by the provider to improve or train its systems, subject to the provider’s own terms, controls, and privacy settings.

Where required by law, we will seek consent or provide appropriate notice before this occurs.

7. Cookies, Consent, and Analytics

Neuovara uses cookies and similar technologies.

7.1 Essential cookies

These are used to:

• keep the website secure
• remember consent settings
• support login, accounts, checkout, or fraud prevention
• maintain core website functionality

These cookies are usually active because the website needs them to work.

7.2 Optional cookies

With your consent, we may also use optional cookies for:

• analytics
• functionality enhancements
• embedded content
• marketing or campaign measurement, if used

7.3 Cookie categories we may use

• Consent cookies to remember your cookie preferences
• Security cookies to protect the website
• E-commerce cookies where store or checkout features are used
• Analytics cookies such as Google Analytics
• Functional cookies for tools like video embeds, fonts, or spam protection
• Marketing cookies where advertising or campaign tools are used

7.4 Consent management

Where required by law, optional cookies are only loaded after you consent to them. You can change or withdraw your consent through our cookie settings tool.

8. Marketing Communications

Where permitted by law, we may send you marketing communications about products, services, events, resources, or updates we believe may interest you.

You can opt out at any time by:

• clicking the unsubscribe link in a marketing email
• changing your account preferences where available
• contacting us at support@neuovara.com

We may still send you non-marketing service messages, such as account notices, payment confirmations, booking reminders, and important updates.

9. When We Share Personal Information

We only share personal information where it is reasonably necessary for our services, required by law, or authorised by you.

9.1 Service providers and processors

We may share personal information with service providers that help us operate Neuovara, such as providers for:

• website hosting and infrastructure
• payment processing
• analytics and consent management
• email and communications
• customer relationship management
• scheduling and webinars
• learning management systems
• community platforms
• cloud storage
• AI services
• technical support, security, and administration

Examples of providers we may use include:

• GoDaddy
• WordPress
• Google Analytics
• Microsoft 365
• PayPal
• Stripe
• ThriveCart
• WooCommerce
• Splose
• Notion
• Make
• Zoom Workplace
• Discord
• Dropbox
• OpenAI / ChatGPT

These providers may process personal information on our behalf and under their own service terms.

9.2 Employees, contractors, and authorised personnel

We may share information with our employees, contractors, counsellors, coaches, consultants, moderators, and support personnel where they need access to provide services, manage support, maintain systems, or protect safety.

Access is limited on a role-based, need-to-know basis.

9.3 Professional advisers

We may share information with our lawyers, accountants, auditors, insurers, bankers, and other professional advisers where necessary.

9.4 Organisation-sponsored access

If your access to Neuovara is provided, paid for, or administered by an employer, provider, school, partner, or other organisation, we may share limited administrative information with that organisation, such as:

• account status
• enrolment status
• login frequency
• course completion totals
• aggregate or de-identified usage information
• billing and support administration information

We do not normally share:

• counselling or coaching content
• the detailed content you viewed
• AI conversation content
• sensitive support information

unless:

• you ask us to
• you clearly consent
• it is necessary for the service you requested
• the law requires it
• it is necessary to protect safety or vital interests

9.5 Other users you authorise

If you choose to share information with another user, coach, caregiver, consultant, or administrator through the services, that information may become accessible to them according to the permissions and settings in place.

9.6 Legal, safety, and compliance disclosures

We may disclose personal information where reasonably necessary to:

• comply with law, regulation, court order, subpoena, or lawful request
• protect our rights, property, systems, or users
• investigate fraud, misuse, or breaches of our terms
• prevent harm
• protect someone’s safety or vital interests

9.7 Corporate transactions

If we are involved in a merger, acquisition, financing, restructure, sale of assets, or similar transaction, personal information may be disclosed as part of that process, subject to appropriate confidentiality and legal safeguards.

9.8 De-identified information

We may use and disclose anonymous, aggregated, or de-identified information for lawful purposes, including analytics, service improvement, and research. We take reasonable steps to ensure that this information cannot reasonably be used to identify you.

9.9 No sale of personal information

We do not sell personal information.

10. International Data Transfers

Neuovara is based in Australia, but some of our service providers, platforms, and technology partners may process personal information in other countries.

This means your personal information may be stored or accessed outside Australia and, if you are in the EEA or UK, outside your home jurisdiction.

Where required by law, we take reasonable steps to protect information transferred internationally, including measures such as:

• provider due diligence
• contractual safeguards
• data processing agreements
• access controls
• encryption
• secure systems and backups
• policies designed to limit unnecessary access

If you are in the EEA or UK and want more information about international transfer safeguards, you can contact us.

11. How We Protect Personal Information

We use reasonable technical and organisational safeguards designed to protect personal information from misuse, interference, loss, unauthorised access, modification, and disclosure.

These measures may include:

• HTTPS / SSL / TLS encryption
• encryption at rest where applicable
• multi-factor authentication for administrators
• role-based permissions
• password hashing
• secure backups
• audit logs
• incident response procedures
• vendor data processing agreements
• confidentiality obligations for staff and contractors
• security monitoring and firewall controls
• subscription and membership access controls for restricted tools and content

No system is completely secure, so we cannot guarantee absolute security.

12. How Long We Keep Personal Information

We keep personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide services, resolve disputes, meet legal obligations, and maintain security.

In general:

• general enquiries may be kept for up to 24 months after the last contact
• marketing records may be kept until you unsubscribe, plus a limited period to maintain suppression records
• account and membership records may be kept while your account is active and for a reasonable period after closure
• transaction and tax records may be kept as required by law, commonly up to 7 years
• counselling, coaching, and support records are kept only as long as reasonably necessary for service delivery, safety, complaints handling, and legal compliance
• AI interaction logs may be retained for different periods depending on the tool used, service settings, and third-party provider terms

When personal information is no longer needed, we take reasonable steps to delete, destroy, or de-identify it.

13. Your Rights and Choices

Depending on where you live, you may have rights in relation to your personal information.

13.1 All users

You may request to:

• access personal information we hold about you
• correct inaccurate or incomplete information
• withdraw consent where processing is based on consent
• unsubscribe from marketing
• change cookie settings
• close your account, subject to legal or operational requirements
• ask questions about how your information is handled

13.2 Australia-specific rights

If Australian privacy law applies, you may request access to or correction of your personal information.

Where lawful and practical, you may also interact with us anonymously or using a pseudonym.

If you believe we have mishandled your personal information, you can make a complaint to us first. We aim to respond within a reasonable time, usually within 30 days.

If you are not satisfied with our response, you may be able to complain to the relevant privacy regulator, such as the Office of the Australian Information Commissioner (OAIC).

13.3 GDPR / UK / EEA rights

If you are in the EEA, UK, or another region with similar rights, you may have the right to:

• access your personal data
• correct inaccurate personal data
• request deletion of personal data
• restrict processing
• object to processing based on legitimate interests
• receive a portable copy of certain personal data
• withdraw consent at any time where processing is based on consent
• lodge a complaint with your local supervisory authority

These rights are not absolute and may be limited in some situations.

13.4 How to exercise your rights

To make a privacy request, contact us at:

support@neuovara.com

We may need to verify your identity before acting on a request.

14. Children

Neuovara is not intended for individuals under 16 years of age.

We do not knowingly collect personal information from children under 16. If you believe a child has provided personal information to us, please contact us and we will take reasonable steps to investigate and, where appropriate, delete the information.

15. Third-Party Links and Services

Our website or services may link to third-party websites, embedded tools, platforms, or social media services.

We do not control how third parties collect or handle personal information. Their use of your information is governed by their own privacy policies and terms.

We encourage you to review those policies before using third-party services.

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal requirements, or privacy practices.

When we make material changes, we may notify users by:

• updating the date at the top of this Policy
• posting the revised version on our website
• sending a notice through email or account notifications where appropriate

17. Contact Us and Privacy Complaints

If you have a question, concern, or complaint about privacy, please contact us:

Spectrum Power Hub Pty Ltd trading as Neuovara
Queensland, Australia
Email: support@neuovara.com

Please include enough detail for us to understand and respond to your request.

We will review privacy complaints carefully and aim to respond within a reasonable time.