OPEN Privacy Policy

1. What is this Privacy Policy?

1. Online Pain Education Network Limited (ABN 95 690 557 236) and Online Pain Education Network Limited Global (ABN 33 694 979 676) of 2 Guilfoyle Avenue, Double Bay NSW 2028 (OPEN, we, us and our) operates a website at https://openpaintraining.com/ (our Website). The Website features information about our modular, interdisciplinary e-learning program designed to educate users and assist in research activity in relation to pain management (the OPEN Program) and the ability to purchase a subscription to the OPEN Program.
2. This Privacy Policy explains how we collect and handle personal information, including when you become a subscriber to the OPEN Program or otherwise use our Website.
3. We may modify or amend this Privacy Policy from time to time. We will display a notice on our Website indicating when any such revisions have been made. This Privacy Policy was last updated on 23 September 2025.
4. Unless you notify us otherwise, we will assume that you have consented to the collection of all information which is provided to us for use in accordance with this Privacy Policy.

2. What is personal information?

Personal information is information or an opinion about an individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in material form or not.

3. Collection of personal information

1. We may collect personal information from you when you become a subscriber to the OPEN Program, subscribe to our newsletter, or otherwise contact us by any method, such as telephone, email, post or in person.
2. When you become a subscriber to the OPEN Program, we will collect the personal information you provide to us during the subscription process or that we subsequently collect in relation to your use of the OPEN Program. Such personal information may include details such as your name, profession and email address. We do not directly collect your credit card details, but use a third party payment processor to do so.
3. When you subscribe to our newsletter, we will collect the personal information you provide to us during the subscription process. Such personal information may include details such as your name, profession and email address.
4. When you access and use our Website we will record and log certain information about such access and use, including your IP address, the date and time of your visit, the parts of our Website you access during your visit, your actions on our Website, and the browser you are using. Where you have subscribed to the OPEN Program, this information may be associated with you, and we may additionally record information about your use and progress through the OPEN Program.
5. As well as collecting information directly from you, there may be occasions when we collect information about you from a third party. For example, we may collect information from a third party where they pay or organise a subscription for the OPEN Program for you, or where they wish to refer you to us for the purpose of offering you a subscription to the OPEN Program.
6. If you are located in New Zealand, we will handle your personal information in accordance with the New Zealand Privacy Act 2020.

4. Anonymity

You do not have to provide us with any personal information if you choose not to. You may use our Website without registering, in which case we will not be able to personally identify you unless you become a subscriber to the OPEN Program or you otherwise provide us with your identity. You can subscribe to our newsletter anonymously or using a pseudonym. You cannot, however, purchase the OPEN Program from us anonymously or using a pseudonym, as the OPEN Program is valuable copyright material and we need to be able to identify the persons who are authorised to use it.

5. Cookies

1. If you use our Website, some of the personal information referred to in section 3 may be collected through the use of cookies. Most browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt you whether you wish to accept cookies on a particular site, or by default reject cookies.
2. Please note that rejecting cookies may mean that some or all of the functions on our Website will not be available to you. In particular, cookies must be enabled to purchase a subscription and register with us, and to access and use the OPEN Program.

6. Purposes for collection and use

We collect, hold, use and disclose personal information provide you with our Website and (if applicable) newsletter, to keep track of your subscription and registration process, and (if you subscribe) to provide you the OPEN Program and record information in relation to your use of the OPEN Program including saving your progress. Personal information collected by us may also be used for the following purposes:

1. to evaluate the performance of our Website, newsletter and the OPEN Program;
2. to provide you with information in relation to the products and services we provide;
3. if you subscribe to our newsletter or the OPEN Program, to send you communications in relation to OPEN and the OPEN Program, and other information that we believe may be of interest to you given the nature of the OPEN Program. If you do not wish to receive such messages, you may opt-out of them by emailing us at info@openpaintraining.com, or using any opt-out functionality that we may provide. Please note, however, that we may still send you service-related messages despite any opt-out;
4. to monitor, investigate and take action in relation to suspicious activity, including any actual or suspected unauthorised use of the OPEN Program;
5. to improve the quality of our Website and the OPEN Program; and
6. as otherwise required or permitted by law.

7. Disclosure of your personal information

1. We may disclose your personal information to third parties in the following circumstances:
   1. to our staff, who may include volunteers, for the purpose of enabling us to conduct our not-for-profit activities;
   2. to contractors and professional advisers engaged to provide goods or services to us (including goods or services that assist us in providing our Website, newsletter or the OPEN Program);
   3. to persons (referred to in our terms of use as “Sponsors”) who may pay for or organise a subscription to the OPEN Program for you;
   4. licensors of content in the OPEN Program, who may audit our licensing of the OPEN Program and compliance of our arrangements with them; and
   5. organisations that may promote the OPEN Program or refer potential users of the OPEN Program to us; and
   6. as otherwise required or permitted by law.
2. At this time, the third parties referred to in paragraph (b) are generally located within Australia, however this may change in the future and if it does we will update this privacy policy accordingly. Personal information may be stored or processed in Australia or other jurisdictions where our service providers operate.

8. Access and correction of your personal information

1. We will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under the Australian Privacy Principles (APPs) or the New Zealand Privacy Act 2020.
2. If you require access to your personal information, please contact us at info@openpaintraining.com. Before we provide you with access to your personal information we will require some proof of identity. For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part.
3. If we refuse to provide you with access to the information, we will provide you with reasons for the refusal (unless it would be unreasonable to do so).
4. We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it. If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.

9. How we hold and secure your personal information

We generally hold personal information in electronic systems maintained by us and our contractors. It may occasionally be held in hard copy form.

The security of your personal information is important to us. We take reasonable steps to prevent the personal information we hold about you from misuse, interference or loss, and from unauthorised access, modification or disclosure. This includes the use of technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of your personal information. As indicated above, we also use a reputable third party payment processor to handle credit card information.

10. Links to other websites

Sometimes our Website contains links to other websites. We do not control and are not responsible for any third-party websites or services you may visit or be directed to. We recommend that you review the terms of use and privacy policies of each third-party website or service you engage with.

11. How to contact us

1. If you have any queries or complaints with regard our collection, use or management of your personal information, please contact us at info@openpaintraining.com.
2. If you have any questions or believe we have not complied with our obligations under the relevant privacy act and you believe that the information we hold about you is incorrect or has been compromised, or you wish to make a complaint about an alleged breach of the Privacy Act, we ask that you send us your complaint in writing to the email address listed above. We endeavour to respond to complaints within a reasonable period (usually 30 days). If you are not satisfied with our response, you may make a complaint to the Office of the Australian Information Commissioner as described on their website www.oaic.gov.au. If you are located in New Zealand and are not satisfied with our response, you may contact the Office of the Privacy Commissioner in New Zealand.

12. Review and Update

This privacy policy was approved by the Board on the 25 September 2025 (approval pending amendments). OPEN will review this privacy policy at least every three years. OPEN may modify or amend this policy at any time. The current version of this privacy policy will be available on the website.