Privacy and Cookie Policy |
Esphere Consulting Pty Ltd (ACN 663 464 757, ABN 87 663 464 757), trading as BA Unfiltered, is committed to protecting your personal information. This policy explains what information we collect, why we collect it, how we use and protect it, and what your rights are. It applies to our course site hosted on Thinkific and to all interactions with BA Unfiltered. We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
1. What Information We Collect
When you create an account or enrol
- Name and email address
- Password (stored encrypted — we cannot access it)
- Country of residence
When you make a purchase
- Billing name and address
- Payment details — processed and stored by Thinkific Payments, not by us. We receive only a transaction confirmation and the last four digits of your card. Where you are an overseas consumer, the transaction record reflects the price paid in the currency of the transaction.
- Purchase amount, course details, and tax invoice information
When you use the course
- Course progress, lesson completion, and time spent on content (tracked by Thinkific)
- Quiz results and scores
- Resource downloads
When you contact us
- The content of your message and any attachments
- Your contact details as provided
Automatically collected information
- IP address and general location (country/region)
- Browser type, device type, and operating system
- Pages visited and navigation behaviour on our site
- Referral source
2. Why We Collect It and How We Use It
We collect only what we need for a specific, stated purpose:
To provide course access — your name, email, and payment confirmation are needed to set up and maintain your learner account.
To process payments — Thinkific Payments handles payment processing on our behalf. We use the transaction record to issue your tax invoice and manage your enrolment.
To track your progress — Thinkific records course progress so you can resume where you left off and access resources gated behind quiz completion.
To communicate with you — we contact you about your enrolment, course updates, technical issues, or in response to your enquiries.
To improve our courses — we use aggregate, non-identifiable usage data to understand content effectiveness.
For marketing — only if you have opted in. You can withdraw consent and unsubscribe at any time.
3. Who We Share It With
We do not sell your personal information. We share it only with service providers who help us deliver our courses:
Thinkific Labs Inc.
Our course platform. Thinkific hosts our site, stores your learner account data, tracks your progress, and issues completion certificates. Data is stored on Amazon Web Services (AWS) servers in the United States. See thinkific.com/privacy-policy for details.
Thinkific Payments
Our payment processor. Thinkific Payments handles all payment card data to PCI-DSS standards, powered by Stripe. We do not store your card details. For BNPL transactions (Afterpay, Klarna, Affirm), those providers also process your data under their own privacy policies.
Email service provider
We use an email service provider to send transactional and (where consented) marketing communications. Your name and email address are shared with this provider for this purpose only.
If you visit external links from our course site or communications, those third-party sites have their own privacy policies. We are not responsible for the privacy practices of third-party sites.
We may also disclose your information if required by Australian law or by a lawful request from a government or regulatory authority.
4. Storing and Protecting Your Information
Your data is stored on Thinkific’s servers, which also handle payment processing via Thinkific Payments. Industry-standard encryption and security controls are in place. We access your data only where necessary to manage your enrolment or respond to a support request.
We retain personal information only for as long as necessary for the purpose it was collected, or as required by law. Financial and transaction records are retained as required under Australian tax law.
If you request deletion of your account, we will delete your personal information within 30 days, subject to our obligation to retain certain records under Australian law.
We comply with our obligations under the Notifiable Data Breaches scheme in the Privacy Act 1988 (Cth).
5. International Transfers
Some of the third-party providers we use (Thinkific, Google) store data in the United States. By using our site and making a purchase, you consent to your personal information being transferred to and stored in the United States for these purposes. These providers maintain appropriate data protection safeguards consistent with Australian Privacy Principle 8.
6. Your Rights Under the Australian Privacy Principles
Under the Privacy Act 1988 (Cth), you have the right to:
- Access the personal information we hold about you
- Ask us to correct information that is inaccurate, incomplete, or out of date
- Ask us to delete your personal information (subject to our legal retention obligations)
- Make a complaint if you believe we have handled your personal information in breach of the Australian Privacy Principles
To exercise any of these rights, email [email protected]. We will 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 oaic.gov.au or call 1300 363 992.
7. Cookies
What cookies are
Cookies are small text files stored on your device when you visit a website. They help the site remember your preferences and how you interact with it.
What cookies we use
Our course site (hosted by Thinkific) uses the following types of cookies:
- Essential cookies — required for the site to function. These keep you logged in, maintain your course progress, and enable checkout. You cannot opt out of these without losing site functionality.
- Analytics cookies — we use Google Analytics to understand how learners navigate the site. Google Analytics uses cookies to collect aggregated, anonymised data about page views, session behaviour, and navigation. No personal profile is built. Analytics cookies are only loaded after you have given consent via the cookie banner on our site. You may withdraw consent at any time by adjusting your cookie preferences on the site. Google Analytics data is sent to Google’s servers in the United States and is subject to Google’s Privacy Policy at policies.google.com/privacy.
- Payment cookies — set by Thinkific Payments during checkout to enable secure payment processing.
- BNPL cookies — if you select Afterpay, Klarna, or Affirm at checkout, those providers may set their own cookies. Their cookie policies apply.
How to manage cookies
You can control cookies through your browser settings. Blocking essential cookies will prevent you from accessing the course site. Blocking analytics or payment cookies may affect checkout functionality.
8. Marketing Communications
We will only send you marketing communications if you have opted in. Each marketing email includes an unsubscribe link. You can also opt out at any time by emailing [email protected]. Opting out of marketing does not affect transactional emails about your enrolment or account.
9. Children
Our courses are intended for adult professional learners. We do not knowingly collect personal information from anyone under the age of 18. If you believe a minor has created an account on our site, please contact [email protected] and we will delete the account promptly.
10. Changes to This Policy
We may update this policy from time to time. The current version with its date will always be posted on our course site. If we make a significant change, we will notify enrolled learners by email.
11. Governing Law
This policy is governed by the laws of the State of Victoria, Australia and the Privacy Act 1988 (Cth).
12. Contact Us
For privacy-related questions, access requests, corrections, or complaints:
- Email: [email protected]
- Entity: Esphere Consulting Pty Ltd ACN 663 464 757
- Address: Point Cook, Victoria, Australia
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at oaic.gov.au or call 1300 363 992.