Privacy Policy

Effective date: 9 October 2026

This policy explains what happens to personal information in connection with the website at subtleshift.online. The responsible entity is ESTAK STAV, s.r.o., Vojenova 2481/7, Libeň, 180 00 Praha 8, Czech Republic, company registration 27217248, contactable at info@subtleshift.online. ESTAK STAV, s.r.o. is not VAT-registered, so no VAT number appears here or anywhere else on the site.

Personal information in connection with this site is handled in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles, which are published by the Office of the Australian Information Commissioner at oaic.gov.au/privacy/australian-privacy-principles.

This policy covers subtleshift.online and nothing else. Links on this site lead to other organisations' websites, including the paid affiliate links to Star Stable Online described on our funding page and the Australian government sites named in the course. Those sites are operated by other people under their own privacy policies, and once you follow a link this policy no longer applies.

The sections below follow the thirteen Australian Privacy Principles in order, so you can see what each one means on a site like this one. Several of them have very little to do here, and where that is the case we say so rather than padding it out.

APP 1 — Open and transparent management of personal information

This document is the whole of our privacy practice; there is no separate internal policy that says something different. It is published at a fixed address, linked from the footer of every page, and written to be read rather than filed. Complaint and enquiry handling is described near the end.

APP 2 — Anonymity and pseudonymity

You can read every page of this site without identifying yourself. There is no account, no login and no form. If you write to us, you may use a pseudonymous email address and need not give your real name — the exception is a request for access to or correction of personal information, where we may need enough information to be satisfied that the records relate to you.

APP 3 — Collection of solicited personal information

Two categories of information exist, and that is all.

The first is server access logs, kept by our hosting provider as an ordinary part of serving a website. A log entry records the IP address of the request, the date and time, the URL requested, the referring page if your browser sends one, and the user-agent string identifying the browser and operating system.

The second is the content of emails sent to info@subtleshift.online: the sending address, any name given, the message itself and any attachments.

Nothing else is collected. There is no contact form, no newsletter, no sign-up, no account, no progress tracking, no quiz and no chat widget. The site sets no cookies and uses no localStorage, sessionStorage or IndexedDB. There is no analytics, no advertising tag, no tracking pixel, no profiling and no cross-site tracking, and the pages load no web fonts, scripts or images from any other server. Your browser makes no request to anyone except the host serving this site.

APP 4 — Dealing with unsolicited personal information

Occasionally an email contains personal information we did not ask for and do not need in order to reply — a phone number, a document attached in passing, details about a third party. Where it is lawful and reasonable to do so, we delete that information rather than keep it. Where it is not, it is treated under this policy like anything else.

APP 5 — Notification of the collection of personal information

This policy is the notification. It is linked from every page of the site, including the Contact page, so that it is available before you write to us, and it names what is collected, why, how long it is kept and who holds it.

APP 6 — Use or disclosure of personal information

Access logs are used for three purposes only: keeping the site secure, preventing and investigating abuse, and diagnosing faults. Email is used for one purpose only: replying to you and dealing with whatever you raised.

Personal information connected with this site is never sold, rented, traded or shared for anyone's marketing. It is disclosed outside the two providers named below only where the law requires it — for example in response to a valid legal process.

APP 7 — Direct marketing

We do not carry out direct marketing. There is no mailing list, no newsletter and no reminder of any kind; writing to us does not add you to anything, and the course sends nobody anything. Nothing on this site exists to build an audience we can contact later.

APP 8 — Cross-border disclosure of personal information

Two providers hold information connected with this site: our hosting provider, which holds the access logs, and our email service provider, which holds correspondence. We do not disclose personal information to anyone else.

Both providers may store or process data outside Australia. We are not naming a country here because we would rather say plainly that the location may be outside Australia than name one that could change without this page being updated. If you would like to know where your correspondence is held before you write to us, ask and we will tell you.

APP 9 — Adoption, use or disclosure of government related identifiers

This principle has no application here. We do not adopt, use or disclose any government related identifier, and there is nothing on this site that could ask you for one.

APP 10 — Quality of personal information

The only information we hold that could be inaccurate is what you have told us in an email. If something you sent us was wrong, or has since changed, write to us and we will correct it. We do not enrich, append to or verify anything against outside sources.

APP 11 — Security of personal information

The site is served over HTTPS. There is no database behind it and no stored submissions, because there is nothing on the site that submits anything — which removes an entire category of risk rather than managing it.

The hosting account and the mailbox are accessible only to people working for ESTAK STAV, s.r.o., and are protected by the access controls those providers offer. We hold no certification and claim no standard beyond this plain description.

Logs and email are destroyed at the end of the retention periods set out below, which is the other half of security: information that no longer exists cannot be disclosed.

APP 12 — Access to personal information

You may ask what personal information we hold about you and receive a copy of it. Write to info@subtleshift.online with Privacy request in the subject line. There is no charge for making a request, and we will respond within 30 days.

In practice, unless you have emailed us, the only thing that could exist is an access log entry, and log entries are not ordinarily linkable to a person without information we do not have.

APP 13 — Correction of personal information

If information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, ask us to correct it using the same address and subject line. We will correct it or, if we disagree that a correction is needed, explain why and note your request on the record. The same 30-day period applies and there is no charge.

Why each category is held, and for how long

Access logs are held for security, abuse prevention and fault diagnosis, and are retained for 30 days. Email is held in order to reply, and is retained for 24 months after the last message in the conversation, unless it is needed for the establishment, exercise or defence of a legal claim, in which case it is kept until that is resolved.

Affiliate links

Some links on this site are paid affiliate links, as described on the Affiliate Disclosure page. When you follow one you leave subtleshift.online. Star Stable Online and the affiliate network that operates the link may use cookies or similar technology on their own sites to record that the referral came from here; that happens on their domains, under their own privacy policies, and we neither control nor see it.

What we receive from the network is commission reporting — counts and amounts. We use it to reconcile payments and for nothing else, and we do not seek, request or attempt to derive information identifying individual readers from it.

Complaints

If you think personal information has been mishandled, write to info@subtleshift.online and we will respond within 30 days. If you are not satisfied with the response, you may complain to the Office of the Australian Information Commissioner at oaic.gov.au/privacy/privacy-complaints, which explains how to make a complaint and what it can do.

Data breaches

If we become aware of unauthorised access to, or disclosure or loss of, personal information connected with this site, we assess it promptly. Where it is likely to result in serious harm, we notify the people affected and the OAIC in line with the Notifiable Data Breaches scheme.

Children

This site is written for adults and is not directed at people under 16. We collect nothing that would identify a child, because we collect nothing that would identify anyone who does not write to us.

Readers in the European Union and the United Kingdom

ESTAK STAV, s.r.o. is established in the Czech Republic, so the following applies in addition for readers to whom European data protection law extends.

The legal basis for keeping access logs is our legitimate interest in keeping the site available, secure and free of abuse. The legal basis for handling email is to respond to the enquiry you have chosen to send. There is no consent basis anywhere on this site, because there are no cookies, no tracking and nothing to consent to.

You have the rights of access, rectification, erasure, restriction of processing, data portability and objection in respect of information we hold. Write to info@subtleshift.online to exercise any of them.

The supervisory authority for ESTAK STAV, s.r.o. is the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů), uoou.gov.cz, to which you may also complain.

Changes to this policy

If this policy is revised, the effective date at the top is updated in the same edit. Where a change is material, a short note saying so is shown at the top of this page for 30 days, so that a returning reader can see that something moved.