Proach Privacy Policy

PROACH PTY LTD – PRIVACY POLICY

Effective date: November 2025

Company: Proach Pty Ltd (ACN: 685 886 784)

Contact: privacy@proach.com

Registered office: Maroochydore QLD 4558, Australia

Proach Pty Ltd (“Proach”, “we”, “us”, “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information in Australia under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Policy applies to all users of the Proach marketplace platform, including Clients and Coaches, and to visitors of our website/app (together, the “Platform”).

1. What we collect

We collect personal information that is reasonably necessary for our functions and activities:

Account & identity data

Name, email, phone number, profile photo, location (city/region), biography, preferences, booking history.
For Coaches: credentials (qualifications, licences, certificates), practice details, ABN, payout details (e.g., account name/BSB/account number—typically via our payment provider), public profile content.

Verification & safety data

Identity verification data (e.g., government ID image, date of birth, liveness/selfie check).
Where used, biometric information (e.g., face templates for liveness) processed by trusted verification providers. We only receive the outcome/metadata we need to decide on access/flags.

Transactional & financial data

Payments are processed by third-party providers (e.g., Stripe). We do not store full payment card numbers.
For Coach payouts, we collect the details needed to set up payment (often stored/tokenised by the provider). We may retain limited identifiers (e.g., last digits) for reconciliation/fraud prevention.

Session & communications data

Booking details (times, durations, prices).
Messages between Clients and Coaches are encrypted in transit and at rest and are accessible only to the participants. Proach may access message content only if a user exports and provides it to us, where both parties consent, where required by law, or where necessary to investigate a credible risk of harm or unlawful activity.

User content & reviews

Ratings, reviews, testimonials, feedback; reports/flags of misconduct.

Technical data

Device/browser, IP address, app version, usage logs, and cookie/analytics data.

Sensitive information

We generally avoid collecting sensitive information (e.g., health information). If you choose to share such information with a Coach during a Session, that is a matter between you and your Coach. If we handle limited sensitive information (e.g., verification data, safety reports), we do so with heightened protections and only as permitted by law.

Children

The Platform is for adults 18+ only. We do not knowingly collect personal information about minors.

2. Why we collect it (uses/purposes)

We use personal information to:

Provide and operate the Platform (accounts, profiles, search, booking, messaging, ratings).
Verify identity and credentials for Coaches; display credential badge states (Verified / Documentation Provided / Self-Reported) for transparency (not endorsement).
Process payments/payouts, handle chargebacks, prevent fraud, and meet AML/CTF compliance obligations with our payment partner(s).
Provide customer support, investigate complaints, and manage disputes.
Safety & misconduct handling (e.g., acknowledge reports within 1 business day and commence investigation within 3 business days; see T&Cs).
Improve the Platform (product analytics, quality assurance, research, and performance).
Communicate service updates, policy changes, and (with consent or as permitted) marketing communications; you can unsubscribe at any time.
Legal compliance (record-keeping, responding to lawful requests, complying with the Privacy Act and other laws).
Record acceptance of terms (we log user ID, timestamp, IP, and version of the Terms/Policies you accepted).

We may use de-identified and aggregated data (that cannot reasonably identify an individual) for analytics, benchmarking, and product improvement.

3. How we collect it

Directly from you when you sign up, complete profile fields, upload credentials, make bookings, message, leave reviews, or contact support.
Automatically via cookies/SDKs/logs when you use the Platform.
From third parties (payment provider results, identity/credential verification services, or where you authorise a data source for verification).

4. Disclosure to third parties

We share personal information with trusted service providers (only to the extent reasonably necessary):

Payments & payouts: Stripe (or equivalent) payment processing and connected-account services.
Identity/credential verification: reputable ID and credential verification vendors.
Hosting & infrastructure: website/app hosting (e.g., Carrd, GoDaddy), cloud infrastructure, app distribution (Apple App Store).
Messaging/communications & support: email/SMS gateway, support ticketing tools.
Analytics & security: analytics platforms, fraud-detection/anti-abuse services.
Professional advisors & regulators: lawyers, auditors, insurers, or regulators (if required or advisable to comply with law, enforce agreements, protect safety/rights, or manage incidents).

We do not sell your personal information.

5. Reviews, community standards & moderation

Reviews must be honest, accurate, and based on genuine experience. No harassment, hate speech, threats, vulgarity/obscenity, doxxing, defamation, spam, or malware/illegal links.
No fake/suppressed/paid reviews. Any permitted incentive must be clearly disclosed where required by law.
We may (but are not obliged to) pre-screen, re-order, refuse, or remove reviews that breach these rules or the law.
We may show aggregated ratings and publish reviews. You grant us a non-exclusive, worldwide, royalty-free licence to host, display, reproduce, and distribute your public reviews/ratings on the Platform and (with consent where required) in marketing for as long as the review is published or reasonably needed for legal/compliance purposes.

6. Cookies & analytics

We use cookies/SDKs and similar technologies to run the Platform, keep you signed in, remember preferences, measure performance, and improve features. You can disable cookies in your browser, but some features may not function. Where required, we will present a cookie notice and let you manage preferences.

7. Marketing

We may send service announcements and, with your consent or as otherwise permitted, marketing communications (email or in-app). You can unsubscribe at any time via the link in the email or your account settings. Transactional/service messages aren’t marketing and will still be sent as needed.

8. Data storage, location & security

We aim to store data in Australia where practicable, but some services may process/store data overseas (see §4). Those providers are chosen for strong privacy/security practices.
We use technical and organisational measures appropriate to the risks: encryption in transit and at rest, access controls, role-based permissions, logging, and least-privilege admin access.
If a Notifiable Data Breach occurs (likely to cause serious harm), we will comply with Australia’s Notifiable Data Breaches (NDB) scheme, including notifying affected individuals and the OAIC as required.

9. Retention & deletion

You can delete your account at any time; personal information is removed from active systems.
We may retain certain records where reasonably necessary for: legal obligations, audit, payment/chargeback reconciliation, fraud prevention, incident management, or ongoing disputes/investigations.
Coach credential/verification materials may be retained for up to 5 years after account closure (or longer if reasonably necessary for an ongoing investigation, dispute, or legal requirement).
We retain de-identified/aggregated data that cannot reasonably be re-identified for analytics and product improvement.

10. Access, correction & rights

You may access or correct your personal information, subject to limited exceptions under the APPs.
Contact: privacy@proach.com (we’ll respond within a reasonable time).

If we decline a request (e.g., it would unreasonably impact others’ privacy), we’ll tell you why (unless legally restricted) and how to complain.

11. Safety, lawful access & disclosures

We prioritise user safety and comply with law. We may access or disclose information only to the extent reasonably necessary to:

respond to credible risks of harm or illegal activity;
comply with court orders, subpoenas, or lawful requests by authorities;
enforce our Terms, protect rights, property, or safety of users or the public; or
manage fraud prevention and abuse on the Platform.

Where disclosure is for safety, we limit it to what is reasonably necessary and proportionate.

12. Third-party tools & links

Sessions may use third-party communication tools (e.g., FaceTime, Google Meet, Zoom). Those services are not controlled by Proach. Their privacy practices are governed by their own policies. We recommend reviewing those policies before use.

13. Changes to this Policy

We may update this Policy to reflect changes in law, technology, or our practices. Material changes will be notified via email and in-app notice at least 7 days before they take effect. Continued use after the effective date constitutes acceptance.

14. Questions, complaints & OAIC

If you have a question or complaint about privacy:

Email: privacy@proach.com
We aim to acknowledge within 1 business day and start investigating within 3 business days.
If you’re not satisfied, you can contact the Office of the Australian Information Commissioner (OAIC): oaic.gov.au or 1300 363 992.

15. Summary of key points (plain English)

We collect only what we need to run Proach, keep people safe, and meet legal/payments obligations.
Payments are handled by third parties (e.g., Stripe); we don’t store card numbers.
Messages are encrypted in transit and at rest and private between participants; limited, safety-/law-based access only.
Coach credentials may be verified; badges show documentation status, not endorsement.
You control your marketing preferences and can delete your account anytime.
We’ll tell you if a notifiable data breach affects you, and you can complain to the OAIC if needed.

Annex – Specific notes for Coaches

By submitting credentials/ID for verification, you consent to processing by our verification providers.
If you withdraw biometric consent (where used for liveness/face match), we may not be able to provide Platform access.
Keep payout details accurate; we’re not responsible for losses from incorrect or outdated payout information.
Do not accept off-Platform payments for Platform-originated bookings; protect Client data and comply with your professional and legal obligations.