How empwr. for firms collects, holds, uses and discloses personal information, under the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
Draft for legal review. This policy has been prepared as a working draft and must be reviewed and approved by a qualified Australian lawyer before it is relied upon. Do not publish without that review.
This Privacy Policy explains how empwr. for firms ("we", "us", "our"), a brand operated by New Wave Group Pty Ltd (ABN to be inserted) of Gold Coast, Queensland, Australia, collects, holds, uses and discloses personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
This policy applies to the website at empwrcoaching.com.au (the "Site"), our coaching program, our community, and the materials and templates we provide to members.
By using the Site or our services, you acknowledge that you have read and understood this Privacy Policy.
Provided by you through the application form, your Gameplan session, program worksheets and the baseline and quarterly reviews. This may include revenue and margin figures, team size and cost, software subscriptions, capacity and utilisation data, and descriptions of your workflows.
This program teaches you to build software inside your own accounts with third-party providers (for example Lovable, Supabase and AI providers). Those accounts are yours, in your name, under your control.
Any client data you load into tools you build is held by you, not by us. We do not access, store or process your clients' data through those tools unless you explicitly share something with us for coaching purposes, for example during a workshop or hot seat. You remain the party responsible for your own clients' data and for your own obligations to them under the Privacy Act and any professional standards that apply to your firm.
Where you do voluntarily share firm or client information with us in a coaching context, we treat it under this policy and ask you to de-identify client information wherever it is not necessary.
We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. Those steps include encrypted transmission, encrypted storage, role-based access controls, secure authentication and periodic security review.
No method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.
We do not sell your personal information. We share it only with providers who help us deliver the service:
| Provider | Purpose | Information shared |
|---|---|---|
| Stripe | Payment processing | Name, email, billing address, payment details |
| GoHighLevel | Website, forms, community, email | Name, email, phone, application responses, community activity |
| Google Analytics | Website analytics (optional) | Anonymised usage data |
We may also disclose information where required by law, regulation, legal process or a governmental request.
While your membership is active we retain your information as necessary to deliver the program. After it ends we retain what we need to meet outstanding obligations. You may request deletion, and we will action it within ninety (90) days, subject to any legal obligation to retain particular records (for example records required under taxation law).
You may request access to the personal information we hold about you by emailing [email protected]. We will respond within thirty (30) days. We may charge a reasonable fee for access where permitted by law.
You may request correction of information that is inaccurate, out of date, incomplete, irrelevant or misleading. Email [email protected] and we will respond within thirty (30) days.
You may request deletion of your personal information at [email protected]. We will process the request within ninety (90) days, subject to legal retention obligations.
If you believe we have breached the APPs or mishandled your personal information, contact [email protected]. We will investigate and respond within thirty (30) days.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au, phone 1300 363 992, email [email protected], or GPO Box 5218, Sydney NSW 2001.
We may use essential cookies required for the Site to function, and optional analytics cookies to understand how visitors use the Site. You can manage cookies through your browser settings. Disabling essential cookies may affect functionality. We respect "Do Not Track" signals where technically feasible.
The Site and our services are not directed to individuals under 18, and we do not knowingly collect their personal information. If we become aware that we have, we will take steps to delete it.
Some of our providers are located outside Australia. Where information is disclosed overseas, we take reasonable steps to ensure the recipient handles it consistently with the APPs. By using our services you consent to that limited cross-border disclosure for the purposes described in this policy.
We may update this policy from time to time. We will notify members of material changes by email, and the updated policy will be posted here with a revised date.
Privacy Officer
empwr. for firms, by New Wave Group Pty Ltd
Email: [email protected]
Gold Coast, Queensland, Australia