Privacy Policy
1. Who we are and what this policy covers
1.1 This policy explains how Nurse Trainer collects, uses, discloses and protects your personal information. Nurse Trainer is Vinod Sasidharan as trustee for the Vinod and Divya Family Trust, ABN 41 902 216 754, of 33 Walter Drive, Thornlands QLD 4164, Australia.
1.2 It applies to www.nursetrainer.org, our learning portal, our live classes, and all communication with us by email, phone, WhatsApp or social media.
1.3 We train nurses and healthcare professionals in many countries. This policy is written to meet Australian privacy law and also the laws that apply where our students live, including in the European Union, the United Kingdom, India, the Middle East, the United States and Canada. Sections 11 to 16 set out the rights that apply in each region.
1.4 Please read this policy together with our Terms and Conditions.
2. Summary
The short version, in plain language:
- We collect the information we need to teach you, contact you and take payment. Nothing more.
- We do not sell your personal information, and we never have.
- We use trusted third party providers to run classes, host materials, send email and process payments. Some are outside your country.
- We only send you marketing if you have agreed, and you can unsubscribe at any time.
- You can ask us what we hold about you, ask us to correct it, and in most cases ask us to delete it.
- If you are unhappy with how we have handled your information, you can complain to us, and then to a regulator in your own country.
3. How we collect your information
3.1 We collect information directly from you when you submit an enquiry form, book a free demo class, enrol in a course, create an account on the learning portal, message us on WhatsApp or email, attend a class, complete an assessment or mock examination, or subscribe to our newsletter.
3.2 We collect some information automatically when you use the Website, through cookies and analytics.
3.3 We may receive information from third parties, including our payment processor, our advertising platforms where you respond to an advertisement, and a person who refers you to us.
3.4 If you give us personal information about another person, for example a referee or an emergency contact, you must have their permission to do so.
4. What we collect
| Category | What it includes | Source |
|---|---|---|
| Identity and contact | Name, email address, phone and WhatsApp number, country and city, preferred language | You |
| Enquiry details | Course of interest, target country of registration, stage of your registration process, preferred class timing, intended start date, your message to us | You |
| Enrolment and account | Username and password, cohort, enrolment date, access period | You and our learning portal |
| Learning and assessment | Attendance, class participation, homework, writing tasks, speaking recordings, practice question results, mock examination scores, progress and readiness tracking, trainer feedback | You and your trainer |
| Payment | Payment confirmation, amount, currency, date, partial card details and billing country. We do not store full card numbers | Payment processor |
| Communications | Emails, WhatsApp messages, call notes, enquiry history, complaint records | You |
| Technical | IP address, device and browser type, pages viewed, referring page, time on site, approximate location derived from IP | Automatically |
| Marketing | Whether you have consented to marketing, whether you opened or clicked an email, which advertisement or campaign you responded to | Automatically and from ad platforms |
4.1 Sensitive information. We do not usually collect sensitive information. We may collect limited health or disability information if you tell us about a condition so that we can make a reasonable adjustment for you, for example during the face to face OSCE intensive. We collect this only with your consent, use it only for that purpose, and delete it when it is no longer needed.
4.2 We do not collect your passport number, visa documents, registration application documents or examination results unless you choose to send them to us, and we ask you not to send them unless we have specifically requested them.
5. Why we use your information, and our legal basis
Where the General Data Protection Regulation applies to you, the right hand column sets out our lawful basis.
| Purpose | Information used | Lawful basis (GDPR) |
|---|---|---|
| To answer your enquiry and advise you on a pathway | Enquiry details, contact details | Steps taken at your request before entering a contract |
| To enrol you, teach you and give you feedback | Enrolment, learning and assessment data | Performance of our contract with you |
| To monitor your progress and tell you when you are exam ready | Assessment and progress data | Performance of our contract with you |
| To take payment and keep financial records | Payment data | Contract, and legal obligation for tax records |
| To support you and respond to problems | Communications, account data | Contract and our legitimate interests |
| To send you marketing about our courses | Contact details, marketing preferences | Your consent |
| To improve our courses, website and teaching | Technical data, aggregated assessment data | Our legitimate interests in improving our services |
| To keep our services secure and prevent misuse | Technical and account data | Our legitimate interests in security |
| To meet legal obligations and handle disputes | Any relevant data | Legal obligation, and establishing or defending legal claims |
5.1 We will not use your information for a new purpose that is unrelated to those above without telling you and, where required, obtaining your consent.
6. Cookies, analytics and advertising
6.1 We use cookies and similar technologies to make the Website work, remember your preferences, measure how the site is used, and measure the effectiveness of our advertising.
| Type | What it does | Consent |
|---|---|---|
| Strictly necessary | Keep the site secure and working, remember your cookie choices | No consent required |
| Analytics, cookieless | Understand how the site is used, without cookies or tracking across sites. We use Cloudflare Web Analytics. | No consent required |
| Analytics, detailed | Understand how visitors use the site in more detail. We use Google Analytics 4. | Consent required in the EU and UK |
| Advertising and measurement | Measure and improve our advertising. We use the Meta Pixel and the Meta Conversions API. | Consent required in the EU and UK |
6.2 You can accept or reject non essential cookies through the banner shown when you first visit, and change your choice at any time. You can also block cookies in your browser, though parts of the site may not work properly. Our Cookie Notice lists each cookie, what it does and how long it lasts.
6.3 Where we advertise on Meta platforms, Meta may use information about your visit to measure and target advertising. Meta acts as an independent controller for some of that processing, and its own privacy policy applies.
7. Who we share your information with
7.1 We share your personal information only as described below. We do not sell it, and we do not disclose it for another organisation's marketing.
| Who | Why | Provider |
|---|---|---|
| Learning platform | Hosts your account, materials, recordings and progress | TrainerCentral, operated by Zoho |
| Live class platform | Delivers live online classes | Zoom, and LiveKit within the TrainerCentral platform |
| Messaging | Enquiries and student support by WhatsApp | WhatsApp Business, operated by Meta |
| Payments | Processes card and other payments | Stripe, PayPal and Google Pay |
| Email and newsletters | Sends enquiry confirmations and newsletters, and stores newsletter subscriber addresses | Resend, operated by Plus Five Five, Inc. (United States) |
| Website analytics | Measures how the website is used | Cloudflare Web Analytics and Google Analytics 4 |
| Website hosting | Hosts the website | Cloudflare Pages, operated by Cloudflare |
| Advertising | Delivers and measures our advertising | Meta Platforms, and any other platform we use |
| Professional advisers | Accountants and lawyers, where necessary | As engaged from time to time |
7.2 We also disclose information where the law requires it, where it is necessary to protect someone's safety, or in connection with a sale or restructure of our business, in which case the recipient must protect it under this policy.
7.3 We require our providers to protect your information and to use it only for the purpose we engaged them for.
8. Sending information overseas
8.1 We are based in Australia. If you are outside Australia, your information will be transferred to and stored in Australia.
8.2 Our service providers may store or process information in the United States, the European Economic Area, India, Singapore and Australia.
8.3 Before disclosing information overseas we take reasonable steps to ensure it is handled consistently with this policy and applicable law. For transfers from the European Economic Area we rely on the European Commission's Standard Contractual Clauses, and for transfers from the United Kingdom on the UK International Data Transfer Agreement or Addendum.
8.4 If you are in a country that restricts transfers of personal data outside its borders, we will seek your express consent to the transfer when you enrol.
9. How long we keep your information
| Type of information | How long we keep it | Why |
|---|---|---|
| Enquiries that do not lead to enrolment | 24 months from your last contact with us | So we can follow up if you return later |
| Student records, including assessments | 7 years from course completion | To confirm attendance and results, and to defend any dispute |
| Financial and tax records | 7 years | Required by Australian tax law |
| Marketing preferences and unsubscribe records | Until you unsubscribe, and then a record of the unsubscribe | To prove we honoured your choice |
| Class recordings | 12 months from the date of the class | So students can review classes they missed |
| Website analytics | 14 months | To understand site performance |
9.1 When information is no longer needed we delete it or de identify it.
10. How we protect your information
10.1 We take reasonable technical and organisational measures to protect your information, including access controls and strong passwords, restricting staff access to what each person needs, encryption in transit, using reputable providers, and training our team on privacy and confidentiality.
10.2 No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we take our obligations seriously and review our practices regularly.
10.3 If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the relevant regulator as required, including the Office of the Australian Information Commissioner under the Notifiable Data Breaches scheme, and supervisory authorities in other regions where applicable.
Your rights
11. Rights that apply to everyone
11.1 Wherever you live, you may ask us to give you a copy of the personal information we hold about you, correct it if it is wrong, delete it where we are not required to keep it, stop sending you marketing, or explain how we have handled it.
11.2 To make a request, email info@nursetrainer.org. We may ask you to verify your identity. We will respond within 30 days, and sooner where the law requires it. There is no charge.
12. Australia
12.1 We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
12.2 You may request access to and correction of your personal information under Australian Privacy Principles 12 and 13. If we refuse a request we will tell you why in writing.
12.3 You may deal with us anonymously or using a pseudonym when making a general enquiry, although we cannot enrol you or teach you without your details.
12.4 If you are not satisfied with how we have handled your information or your complaint, you may contact the Office of the Australian Information Commissioner at oaic.gov.au, by phone on 1300 363 992, or by post to GPO Box 5218, Sydney NSW 2001.
13. European Union, Ireland and the United Kingdom
13.1 Where the General Data Protection Regulation or the UK GDPR applies, you have the right of access, rectification, erasure, restriction of processing, data portability, objection to processing based on legitimate interests, objection to direct marketing at any time, and withdrawal of consent at any time without affecting processing already carried out.
13.2 We have not appointed a representative under Article 27 of the GDPR or the UK GDPR. You can contact us directly using the details in section 22, and we will handle your request as we would if a representative had been appointed.
13.3 You may complain to your local supervisory authority. In Ireland this is the Data Protection Commission at dataprotection.ie. In the United Kingdom it is the Information Commissioner's Office at ico.org.uk.
14. India
14.1 Where you are in India, we process your digital personal data in accordance with the Digital Personal Data Protection Act 2023 and the Digital Personal Data Protection Rules 2025. This policy is the notice required under that Act.
14.2 We process your data on the basis of your consent, which is free, specific, informed, unconditional and unambiguous, and given by a clear affirmative action. You may withdraw it at any time, and doing so is as easy as giving it.
14.3 You have the right to access a summary of your data and how it is processed, to correction, completion, updating and erasure, to nominate another person to exercise your rights if you die or become incapacitated, and to a grievance process.
14.4 Our Grievance Officer is Divya K T Sarath Chandran, Chief Operations Officer, Nurse Trainer. You can contact her at info@nursetrainer.org or on +61 448 041 657. We will respond to a grievance within 30 days.
14.5 If your grievance is not resolved, you may complain to the Data Protection Board of India.
15. Middle East
15.1 Where you are in the United Arab Emirates, Saudi Arabia, Qatar, Oman, Bahrain or Kuwait, we handle your personal data in accordance with this policy and applicable local law, including the UAE Personal Data Protection Law and the Saudi Personal Data Protection Law where they apply to you.
15.2 You may request access, correction, deletion and restriction of processing, and may object to processing, by contacting us at info@nursetrainer.org.
15.3 Where local law requires your express consent before your data leaves the country, we will ask for it at enrolment.
16. United States and Canada
16.1 If you are in the United States, depending on your state you may have the right to know what personal information we collect and why, to request a copy, to request correction or deletion, and to opt out of sale or sharing of personal information and of targeted advertising. We do not sell personal information and we do not share it for cross context behavioural advertising other than through the advertising cookies described in section 6, which you can reject.
16.2 We will not discriminate against you for exercising a privacy right.
16.3 If you are in Canada, we handle your personal information in accordance with the Personal Information Protection and Electronic Documents Act, and with Quebec's Law 25 where it applies to you. You may complain to the Office of the Privacy Commissioner of Canada, or to the Commission d'accès à l'information du Québec.
Other important information
17. Marketing and communications
17.1 We send marketing only where you have consented, in line with the Spam Act 2003 (Cth) and the equivalent laws that apply where you live.
17.2 Every marketing email includes an unsubscribe link, and we action unsubscribe requests promptly and at no cost. You can also unsubscribe by replying to any message or emailing info@nursetrainer.org.
17.3 We will still send you service messages about a course you are enrolled in, such as class times, materials and payment receipts. These are not marketing and you cannot unsubscribe from them while you are enrolled.
17.4 If you contact us on WhatsApp we will reply on WhatsApp. We will not add you to a marketing broadcast list without your consent, and you can ask us to stop messaging you at any time.
18. Progress monitoring and automated processing
18.1 We track your attendance, practice results and mock examination scores to advise you on your readiness to sit an examination. This is our Personalised Performance Monitoring process.
18.2 Readiness decisions are made by your trainer, using this information as a guide. We do not make decisions that produce legal or similarly significant effects about you based on automated processing alone, and you may always ask your trainer to explain a readiness assessment and to review it.
18.3 Where any part of this process becomes automated, we will describe it in this policy and, where the law requires, offer you a right to human review.
19. Children
19.1 Our courses are for adults. We do not knowingly collect information from anyone under 16. Where a student aged 16 or 17 enrols with the written consent of a parent or guardian, we collect only what is needed to provide the course.
19.2 If you believe a child has given us personal information, contact us and we will delete it.
20. Complaints
20.1 If you are concerned about how we have handled your personal information, contact us at info@nursetrainer.org. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.
20.2 If you are not satisfied with our response, you may complain to the regulator in your region, as set out in sections 12 to 16.
21. Changes to this policy
21.1 We may update this policy. The current version is always on this page, with the date it was last updated. Where a change is material we will tell you by email or by a notice on the Website before it takes effect.
21.2 We keep dated copies of earlier versions and can provide one on request.
22. Contact us
Nurse Trainer · Vinod Sasidharan as trustee for the Vinod and Divya Family Trust · ABN 41 902 216 754
33 Walter Drive, Thornlands QLD 4164, Australia
Privacy enquiries, access requests and grievances:info@nursetrainer.org
Phone and WhatsApp: +61 448 041 657
Grievance Officer for the purposes of the Indian Digital Personal Data Protection Act: Divya K T Sarath Chandran, Chief Operations Officer.