1. Introduction

Welcome to Tholmarewhral, operated by NightUnplug. We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website tholmarewhral.world and use our screen-free evening programs and services.

By accessing or using our website and services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our services.

This Privacy Policy complies with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and applies to all personal information we collect from Australian residents and international users of our services.

2. Information We Collect

2.1 Personal Information You Provide

We collect information that you voluntarily provide to us when you:

• Register for our screen-free programs or services
• Fill out contact forms or inquiry submissions
• Subscribe to our newsletters or communications
• Participate in surveys, feedback forms, or testimonials
• Communicate with us via email, phone, or other channels
• Attend our workshops or in-person consultations
• Make purchases or payments for our programs

The personal information we may collect includes:

• Full name and contact details (email address, phone number, postal address)
• Demographic information (age, gender, location)
• Sleep patterns and habits information (voluntarily provided for program customization)
• Evening routine preferences and screen usage patterns
• Payment and billing information
• Communication preferences and history
• Any other information you choose to provide in forms or communications

2.2 Automatically Collected Information

When you visit tholmarewhral.world, we automatically collect certain technical information about your device and how you interact with our website:

• IP address and geolocation data
• Browser type, version, and settings
• Device type, operating system, and unique device identifiers
• Pages viewed, links clicked, and navigation paths
• Time and date of visits, time spent on pages
• Referring website addresses and search terms used
• Cookies and similar tracking technologies (see Cookie Policy for details)

2.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment processors and financial institutions
• Analytics providers and advertising partners
• Social media platforms (if you interact with our content)
• Publicly available sources and databases

3. How We Use Your Information

We use the information we collect for various purposes related to providing and improving our screen-free programs and services:

3.1 Service Delivery

• To provide, operate, and maintain our website and services
• To process your registration and enrollment in programs
• To deliver program materials, resources, and guidance
• To personalize your experience and customize program recommendations
• To facilitate coaching sessions and community interactions
• To process payments and manage billing

3.2 Communication

• To respond to your inquiries, questions, and support requests
• To send program updates, reminders, and progress tracking
• To provide customer service and technical support
• To send newsletters, educational content, and promotional materials (with your consent)
• To notify you of changes to our services, policies, or terms

3.3 Improvement and Development

• To analyze usage patterns and improve our website and programs
• To conduct research and develop new services
• To understand user preferences and optimize content
• To test new features and functionality
• To gather feedback and testimonials

3.4 Security and Legal Compliance

• To protect against fraud, unauthorized access, and security threats
• To enforce our Terms of Use and other agreements
• To comply with legal obligations and regulatory requirements
• To respond to legal requests and prevent harm

4. Legal Basis for Processing

Under Australian privacy law and international data protection regulations, we process your personal information based on the following legal grounds:

• Consent: You have given clear consent for us to process your personal information for specific purposes
• Contract Performance: Processing is necessary to fulfill our contractual obligations when you enroll in programs
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as improving services and preventing fraud
• Legal Obligations: Processing is required to comply with applicable laws and regulations

5. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. We may share your information only in the following circumstances:

5.1 Service Providers

We work with trusted third-party service providers who assist us in operating our website and delivering services. These providers may access your information only to perform specific tasks on our behalf and are obligated to protect your information:

• Website hosting and cloud storage providers
• Payment processors and financial service providers
• Email service providers and communication platforms
• Analytics and data analysis services
• Customer relationship management systems
• IT support and security services

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Court orders, subpoenas, or legal processes
• Government or regulatory authority requests
• Enforcement of our rights or protection of safety
• Investigation of fraud or security issues

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

5.4 With Your Consent

We may share your information with third parties when you have given explicit consent for such disclosure.

6. Data Security

We implement comprehensive security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. Our security practices include:

• Encryption of data in transit using SSL/TLS protocols
• Secure storage of data with encryption at rest
• Regular security assessments and vulnerability testing
• Access controls and authentication requirements
• Employee training on data protection and confidentiality
• Incident response procedures and breach notification protocols
• Regular backups and disaster recovery planning

While we strive to protect your information using industry-standard security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to protecting your data to the best of our ability.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Account and program enrollment data: Duration of your participation plus 7 years for legal and accounting purposes
• Communication records: 3 years from last contact
• Payment and transaction data: 7 years as required by Australian tax law
• Marketing communications: Until you unsubscribe or request deletion
• Website analytics: 26 months from collection

When personal information is no longer needed, we securely delete or anonymize it in accordance with our data retention and disposal policies.

8. Your Privacy Rights

Under Australian privacy law, you have the following rights regarding your personal information:

8.1 Access

You have the right to request access to the personal information we hold about you. We will provide you with a copy of your data in a commonly used format.

8.2 Correction

You have the right to request correction of inaccurate, incomplete, or outdated information. We will make reasonable efforts to update your information promptly.

8.3 Deletion

You have the right to request deletion of your personal information, subject to certain legal exceptions such as record-keeping obligations.

8.4 Objection and Restriction

You have the right to object to certain types of processing and request restriction of processing in specific circumstances.

8.5 Data Portability

You have the right to receive your personal information in a structured, commonly used, machine-readable format and transmit it to another service provider.

8.6 Withdraw Consent

Where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.

8.7 Opt-Out of Marketing

You can unsubscribe from marketing communications at any time by clicking the unsubscribe link in emails or contacting us directly.

To exercise any of these rights, please contact us using the information provided in Section 13. We will respond to your request within 30 days.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on tholmarewhral.ddd. For detailed information about the cookies we use and how to manage them, please see our separate Cookies Policy.

10. Third-Party Links

Our website may contain links to third-party websites, including payment processors, social media platforms, and partner organizations. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

11. Children's Privacy

Our services are intended for adults aged 18 and over. We do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected information from a child, please contact us immediately, and we will take steps to delete such information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. When we make changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you via email if the changes are significant
• Post a notice on our website homepage
• Obtain your consent where required by law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our services after changes are posted constitutes acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

14. Complaints

If you believe we have breached your privacy rights or the Australian Privacy Principles, you have the right to lodge a complaint with us. We take complaints seriously and will investigate promptly.

To lodge a complaint, please contact us using the information above and provide details of your concern. We will acknowledge receipt of your complaint within 7 days and aim to resolve it 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):

15. International Data Transfers

Your information may be transferred to and stored on servers located outside Australia, including in countries that may not have equivalent data protection laws. When we transfer data internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by regulatory authorities
• Adequacy decisions confirming appropriate protection levels
• Binding corporate rules for intra-group transfers
• Your explicit consent for specific transfers

16. Automated Decision-Making

We may use automated systems to analyze your information and provide personalized program recommendations. You have the right to request human review of any automated decisions that significantly affect you.

17. Do Not Track Signals

Some browsers include a "Do Not Track" feature. Our website does not currently respond to Do Not Track signals. You can control cookies and tracking through your browser settings as described in our Cookies Policy.