Privacy Policy

This Privacy Policy explains how Brain Based Therapies Pty Ltd (“Brain Based Therapies”, “we”, “us”, “our”) collects, uses, discloses and protects personal information when you use the Orbital website at orbital.brainbasedtherapies.org (the “Site”), enquire about the Orbital device, sign the Confidentiality Deed, or access the practitioner library.

We are an Australian company based in Eden, New South Wales, and we handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1. Information we collect

We collect personal information that you provide to us directly, including:

• Enquiries & access requests. When you submit an enquiry or request access to the library, we collect your name, clinic or organisation, professional role, email address, phone number (if provided), the region you are enquiring from, your enquiry type and any message you send us.
• Confidentiality Deed. When you sign the Confidentiality Deed, we collect your name, email address, organisation and your electronic signature (typed or drawn), together with an audit record — the date and time of signing, a cryptographic hash of the document content, and a hashed representation of your IP address — for authenticity and record-keeping.
• Member accounts. If you are invited to and create a portal account, we hold your name, email, organisation, professional role, a securely hashed password, and a record of which resources you have viewed and when (used to show your progress and to protect confidential materials).
• Subscriptions. If you ask to receive updates or materials, we collect your name and email address for that purpose.

We also collect limited technical information automatically:

• Network & device data. Our hosting and security provider records information such as your IP address, approximate country, browser type and access times to operate the Site, prevent abuse and maintain security.
• Cookies. We use a strictly necessary session cookie to keep you signed in to the members portal. We do not use advertising or third-party tracking cookies.

2. How we use your information

• To respond to your enquiries and provide information, pricing and documentation.
• To assess and process requests for access to the practitioner library.
• To create and administer member accounts and provide access to resources.
• To record and verify signed Confidentiality Deeds and enforce confidentiality.
• To track resource views for security, IP protection and to show your progress.
• To send you materials or updates you have requested.
• To operate, secure and improve the Site and to comply with our legal obligations.

3. Disclosure of your information

We do not sell your personal information. We disclose it only where necessary:

• Service providers. We use trusted third parties to run the Site — including Cloudflare (hosting, database, file storage and security) and Resend (transactional email). Embedded training videos are served via YouTube (in privacy-enhanced “no-cookie” mode). These providers process data on our behalf under their own terms.
• Authorised distributors. Where your enquiry relates to a region served by an authorised distributor (for example, India and the subcontinent), we may forward your enquiry to that distributor so they can assist you.
• Legal. Where required or permitted by law, or to establish, exercise or defend legal rights (including under a Confidentiality Deed).

Some of these providers may store or process data outside Australia. Where that occurs, we take reasonable steps to ensure your information is handled consistently with the APPs.

4. Storage and security

We take reasonable steps to protect personal information from misuse, loss and unauthorised access. Passwords are stored only as salted, one-way hashes. Signed deeds and library files are held in access-controlled storage and served only to authenticated users; library documents are made viewable rather than downloadable and may carry a personalised watermark. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

5. Retention

We keep personal information for as long as needed for the purposes described above or as required by law. Signed Confidentiality Deeds and their audit records are retained for the period we may need to rely on them. We delete or de-identify information when it is no longer required.

6. Your rights

You may request access to, or correction of, the personal information we hold about you, and you may ask us to stop sending you materials at any time. To make a request, contact us using the details below. We will respond within a reasonable time. If you are not satisfied with how we have handled your information, you may complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

7. Children

The Site is intended for healthcare professionals and organisations and is not directed at children. We do not knowingly collect personal information from children.

8. Changes to this policy

We may update this Privacy Policy from time to time. The current version is always available on this page, with the “last updated” date shown above.

9. Contact us

Brain Based Therapies Pty Ltd
Eden, New South Wales, Australia
Enquiries: via our contact form

This policy is provided for general information and should be reviewed by the company’s legal adviser (and the company ABN inserted) before it is relied upon.