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We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect Personal Data on the Services, and how you can exercise your privacy rights. By using the Services, you confirm that you understand and agree with this Privacy Policy. If you do not agree, you may not use the Services.
We adopt the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure, and dispose of your Personal Data. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/privacy/australian-privacy-principles.
This Privacy Policy, together with our Terms & Conditions, forms a legally binding agreement between you and us. Capitalised terms not defined in this Privacy Policy have the meaning given to them in the Terms & Conditions.
Please carefully read this Privacy Policy because it affects your rights under the law. By using the Services, you confirm that you understand and agree with this Privacy Policy. If you do not agree, you may not use the Services.
This Privacy Policy was last updated on 27 July 2024. Your continued use of the Services after any changes to the Privacy Policy indicates your acceptance of the Privacy Policy.
1.1. The Privacy Act defines “Personal Data” as information or an opinion about an identified individual, or an individual who is reasonably identifiable.
1.2. Our policy is to minimize the amount of Personal Data that we collect. We only collect Personal Data that is adequate, relevant, and limited to what is reasonably necessary for the purposes for which it is processed.
2.1. We collect the following Personal Data when you sign up for our coaching services: first name, last name, email address, and phone number (“Account Data”). This information is used to create your account and provide you with our Services.
2.2. We use Account Data to set up and verify your Accounts and whenever required for your use of the Services.
2.3. If you opt not to provide any Account Data or not register for an Account, you may only browse limited pages of our Services.
2.4. We do not collect sensitive personal information.
2.5. We do not collect or store information of third-parties without their consent. If you provide us with the Personal Data of any person other than yourself, you must ensure that you have the authority to do so and inform them about this Privacy Policy.
3.1. Non-Personal Data is information that does not personally identify a person; but may include tracking information about the use of the Services such as devices, location, and demographics. When you interact with the Services, we collect and store the following Non-Personal Data: analytics data, log files, device identifiers, and location data.
4.1. We use information only for the reasons it is collected. We process information only for the purposes specifically stated in this Privacy Policy. We process the information we collect about you for the purposes set out below:
4.1.1. Provide the Services. We use the information that you directly give us to operate and maintain the Services. We also use it to remember your information so that you do not have to re-enter it when you login to the Services or request additional Services.
4.1.2. Data analytics. We use information about you to help us improve the Services and our users’ experience, including aggregate metrics which allow us to observe user engagement and refine communications.
4.1.3. Communicating with you. We use your contact information to communicate with you about important aspects of our Services, such as technical issues, security alerts, and administrative matters. Additionally, we inform you about coaching session schedules, times and dates, and any cancellations. We also respond to emails from our clients to provide additional coaching support.
4.1.4. Security measures. We use Non-Personal Data to monitor activity that we think is suspicious or potentially fraudulent, and to identify violations of this Privacy Policy.
4.1.5. Matters that you specifically consent to. From time to time, we may seek your consent to use your information for a particular purpose. Where you consent to our doing so, we will use it for that purpose. Where you no longer want us to use your information for that purpose, you may withdraw your consent.
4.2. We will not process Personal Data that was collected in a manner incompatible with these purposes. We never sell Personal Data.
5.1. Our Affiliates. We share Personal Data with our affiliates that we control that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.
5.2. Third-Party Service Providers. We employ other companies and individuals to perform functions on our behalf. Examples include sending communications, analysing data, providing marketing and sales assistance, conducting customer relationship management, and providing training. These third-party service providers have access to Personal Data needed to perform their functions, but may not use it for other purposes. Further, they must process that information in accordance with this Privacy Policy and as permitted by applicable data protection laws.
5.3. Payment Supplier. Your payment information is stored and processed by Calendly, Stripe, PayPal or other third-party payment service providers that we use on the Services (each, a “Payment Supplier”). For more information about their privacy practices, please see https://calendly.com/legal/privacy-notice and https://stripe.com/privacy and https://www.paypal.com/myaccount/privacy/privacyhub. We do not have and will never have access or control to your payment information. The Payment Supplier will only be provided with access to your information as reasonably necessary for the purpose for which we have engaged the Payment Supplier.
5.4. Merger, Acquisition or Reorganization. We may share or transfer your Personal Data to third-parties in connection with any merger, acquisition, reorganization, financing, sale of assets, bankruptcy, or insolvency event involving us or any portion of our assets, services, or businesses. If your Personal Data will be shared, transferred, or handled differently than under the privacy practices in this Privacy Policy, we will notify you through email and/or the Services.
5.5. Authorities. We will use or disclose your information when we reasonably believe that it is necessary (a) to comply with the law and the reasonable requests of law enforcement, (b) to enforce our Terms & Conditions, and/or (c) to exercise or protect our rights, property, or personal safety, of our users, or of other persons.
5.6. We neither use, aggregate, or anonymise your Personal Data nor share it with any other person or third-parties not stated in this Privacy Policy.
6.1. We process Personal Data in a manner that ensures its appropriate security, including by protecting the Personal Data with the technical or organisational measures against unauthorised or unlawful processing and accidental loss, destruction, or damage.
6.2. We have prepared a response plan for addressing data breaches that may occur and have allocated responsibility for managing breaches to a relevant individual or team. We will notify you of any data breach that may affect you where we are required to do so under our legal obligations.
6.3. However, no system is 100% secure. We cannot ensure or warrant the security of any information you transmit through the Services or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed. You are responsible for maintaining the security of your login information.
7.1. We do not keep Personal Data longer than necessary to process the data. After the purpose for which your Personal Data is processed has ended, we will delete the Personal Data within the period required by applicable data protection laws; except if we need to retain the Personal Data to comply with our legal obligations or to protect any person's vital interests.
7.2. If any applicable data protection law requires us to retain the Personal Data for longer than necessary, we will notify you of that requirement and use only such retained Personal Data for the purposes of complying with those applicable laws.
7.3. When allowed by applicable law, we will take reasonable steps to de-identify and store your Personal Data in a manner that does not allow identification of individuals.
8.1. Provided that we comply with the provisions of the Australian Privacy Principle 8 (Cross-border disclosure of Personal Data), your information collected through the Services may be stored and processed in Australia and any other countries where we or our subsidiaries, affiliates, or service providers maintain facilities or employ staff or contractors. As a result, we may transfer information, including Personal Data, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. Nevertheless, we always take steps to ensure that your information remains protected wherever it is stored and processed in accordance with applicable laws.
8.2. Where required under applicable laws, by using the Services, you consent to the transfer of information to Australia and any other country in which we or our subsidiaries, affiliates, or service providers maintain facilities. Further, by using the Services, you consent to the use and disclosure of information about you as described in this Privacy Policy.
9.1. Subject to the provisions and exceptions set out in the Privacy Act 1988 (Cth), you have the following rights with respect to your Personal Data:
9.1.1. to access, correct, or erase;
9.1.2. to restrict the processing;
9.1.3. to object to the processing;
9.1.4. to data portability;
9.1.5. to withdraw consent;
9.1.6. to lodge a complaint with the appropriate supervisory authority;
9.1.7. to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or it similarly significantly affects you.
9.2. If you want to exercise any of your rights, please contact us at lu@lucindacoaching.com. We will handle all such requests per our legal obligations.
9.3. In some circumstances, we will not be able to comply with your request regarding your Personal Data. If we are unable to remove any of your information, we will explain why. For example, we may not be able to provide a copy of your information where it infringes on the rights of another user. In that case, we will not be able to delete the information, and you will need to contact that third-party directly.
9.4. If, as a result of the exercise of the above rights, it would not be possible or practical for us to continue providing you the Services, we may terminate your Account.
10.1. If you believe there has been a breach of your privacy or would like to make a complaint, please contact us. We will aim to investigate and respond to complaints within 28 days of receiving the complaint. If we require more time to investigate a complaint, we will let you know when we expect to be able to provide a response.
10.2. If you are not satisfied with the outcome of a complaint, or if you are concerned about a potential violation, you also have the option to report the issue or make a complaint to the data protection authority in your jurisdiction. You may refer the complaint to the Office of the Australian Information Commissioner (OAIC), which can be contacted at Address: GPO Box 5218, Sydney NSW 2001, Phone: 1300 363 992, Email: enquiries@oaic.gov.au.
11.1. We do not send “junk” or unsolicited emails in contravention of the Spam Act 2003 (Cth). We will, however, use email in some cases to respond to inquiries or contact our users. These transaction-based emails may be automatically generated. If you want to opt-out of any communications from our Services, please contact us.
12.1. We would like to send you information about our services that we think you might like. If you have agreed to receive these marketing materials, you can always opt-out. You have the right at any time to stop us from contacting you for marketing purposes.
14.1. Cookies are small data files containing an identifier (a string of letters and/or numbers) that is passed from the web server to the user’s web browser when visiting a site. A cookie remains valid until its expiration date, unless the user deletes (“clears”) the cookies from the browser. The Services uses different types of cookies and tracking technologies.
14.2. Technical Cookies. The Services uses cookies for the technical requirements and functionalities, such as for operating it, authenticating your logins, and granting you access to your Account.
14.3. Functional Cookies. The Services use cookies to tailor your interactions within the Services so we can provide you with a better user experience. For example, we use cookies to remember your previous selections or choices.
14.4. Tracking Cookies. The Services uses cookies and various tracking technologies to automatically collect analytics data and information about the device that you use to access the Services, IP address, browser type, date, and time associated with each open and click and other information regarding your computer system, activity, and connection when you use the Services. We also collect information regarding the performance of the Services, including metrics related to communication deliverability, such as emails and other electronic communications you send through the Services. This data is usually viewed in aggregated form to provide general behaviours of the users.
14.5. Web Beacons or Clear GIFs. Web beacons are tiny graphic files that contain unique identifiers typically used by third-parties to monitor the activity of users at a website. We use web beacons to recognise whether the emails sent from the Services have been delivered, opened, clicked on, bounced, or spammed. This critical function allows us to measure the performance of the emails sent from the Services, track the online usage patterns of our users, provide analytics information, gather more accurate reporting, and enhance the effectiveness of the Services.
15.1. First-Party Cookies. First-party cookies are the ones we directly serve to your computer or device. The cookies that we use do not typically contain any Personal Data that can identify you. Still, the Personal Data that we store about you on our Services may be linked back to your cookie information.
15.2. Third-Party Cookies. Third-party cookies are cookies set by other parties. Third-party cookies enable additional features or functionalities to be provided by third-parties on or through the Services (such as added functionality, payment processing, usability improvements, analytics, and recognising your computer or device). We host the Website on Webflow. For more information about the privacy and cookie policies of Webflow, please check https://webflow.com/legal/privacy.
16.1. You have the right to decide whether to accept or reject cookies. Most browsers allow you to refuse to accept cookies and delete or “clear” cookies. While the methods for doing so vary based on browser and version, you can review current information from your browser’s help menu for more information.
16.2. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Blocking all cookies will negatively impact, or in some cases, disable features of many websites, including our Services.
16.3. If you have disabled one or more cookies, we will stop using the disabled cookie to collect any further information. Still, we will use the information that we have previously collected.
17.1. Some browsers include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Services do not currently respond to “DNT” signals. We will continue to monitor developments around DNT browser technology and the implementation of standard signals. To learn more about “DNT”, please visit All About Do Not Track (https://fpf.org/thank-you-for-visiting-allaboutdnt-com/).
18.1. The Services are not directed at children under the age of 18. We do not knowingly collect or solicit Personal Data from children. If we learn that we have collected Personal Data from a child under the age of 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 18, please contact us at lu@lucindacoaching.com.
19.1. We may periodically change this Privacy Policy to reflect our current practices and ensure compliance with applicable laws. The most updated version is posted on this page. We recommend that you check this page from time to time for any changes. If you have an Account, we will send a notification about the changes to the email address in your Account.