Privacy Policy

PURPOSE

This Privacy Policy explains how Actually Pty Ltd (“Company”, “we”, “our”, “us”) collects, uses, stores, shares, protects, and manages personal information.

This Policy applies to users of our website, educational offerings, wellness guidance services, courses, sessions, community platforms, newsletters, and related services (“Services”).

We aim to handle information responsibly and in accordance with applicable Australian privacy obligations.

2. WHO THIS POLICY APPLIES TO

This Policy applies to:

• parents and legal guardians
• youth participants aged 11+
• website visitors
• course participants
• community members
• newsletter subscribers

The contractual relationship exists with the parent or legal guardian.

3. CHILDREN AND YOUTH INFORMATION

Our Services involve participation by minors.

Parents or legal guardians must provide consent before youth participate.
Parents represent that they have authority to:

• provide participant information
• consent to recordings where applicable
• manage participation
• consent to communications

Youth participation may also involve age-appropriate agreement and explanation where appropriate.

4. INFORMATION WE COLLECT

We may collect Identity Information:
• names
• email addresses
• phone numbers
• age range
• parent details

Participation Information:
• booking details
• attendance
• course participation
• session history
• submitted forms

Wellbeing and Program Information:
• goals
• preferences
• accommodations requested
• voluntary information shared during participation

Technical Information:
• IP address
• browser information
• device information
• analytics

Community Information:
• posts
• comments
• uploaded materials

Recording Information:
• video
• audio
• chat interactions
• session participation data

Marketing Information:
• newsletter preferences
• campaign interactions

5. HOW WE COLLECT INFORMATION

Information may be collected:

• directly from parents
• during intake
• during bookings
• during sessions
• through forms
• through website use
• through communities
• through email subscriptions
• through course platforms

6. WHY WE COLLECT INFORMATION

We collect information to:

• deliver Services
• manage participation
• communicate with families
• provide replays and course access
• improve offerings
• ensure safeguarding
• provide technical support
• meet legal obligations
• send newsletters and updates

7. RECORDINGS

Certain Services may involve recording.
Recording notice will be provided before recording occurs.
Recordings may be used for:

• replay access
• educational continuity
• safeguarding
• quality improvement
• participant access

Participants must not redistribute recordings.
Replay availability periods may be limited.

Where consent is withdrawn, future recording participation may be adjusted where operationally possible.
We cannot guarantee removal of content already accessed by authorised participants.

8. COMMUNITY SPACES

Parents and authorised youth may access community spaces.
Community participation is voluntary.
Users should avoid posting:

• highly sensitive information
• personal health information
• information about third parties

We cannot guarantee complete confidentiality within community environments.
The Company may moderate or remove content.

9. EMAIL COMMUNICATIONS

We may send:

• booking communications
• program communications
• newsletters
• educational content
• promotional information

Users may unsubscribe from marketing emails at any time.
Service communications may still be sent.

10. . COOKIES AND WEBSITE TECHNOLOGY

We may use:

• essential cookies
• analytics tools
• marketing technologies
• preference cookies

These technologies help operate and improve Services.
Users may adjust browser settings.
A separate Cookie Policy may apply.

11. . DISCLOSURE OF INFORMATION

We may disclose information to:

• payment processors
• scheduling providers
• video platforms
• course providers
• email systems
• technical providers
• legal advisors

We may disclose information where:

• required by law
• safeguarding concerns arise
• lawful requests are received

We do not sell personal information.

12. . OVERSEAS PROCESSING

Some service providers may process information outside Australia.
By using Services, users acknowledge that information may be transferred internationally.
We aim to use reputable providers with appropriate safeguards.

13. . STORAGE AND SECURITY

We take reasonable steps to protect information.
Measures may include:

• restricted access
• secure platforms
• password controls
• administrative procedures

No system is completely secure.
Users should protect their own devices and credentials.

14. . RETENTION

We retain information only as long as reasonably necessary for:

• service delivery
• legal compliance
• safeguarding
• business administration

Recordings may have separate retention periods.

15. . ACCESS AND CORRECTION

Parents may request:

• access to information
• corrections
• updates

Requests may be declined where legally permitted.

16. . DELETION REQUESTS

Parents may request deletion of information.
We may retain information where necessary for:

• legal obligations
• safeguarding
• dispute resolution
• legitimate business records

17. . THIRD-PARTY LINKS

Our website may contain external links.
We are not responsible for external privacy practices.

18. . CHANGES TO THIS POLICY

We may update this Policy.
Updates become effective upon publication.

19. . CONTACT

Privacy Contact
Actually Pty Ltd
Email: contact@divergentguids.com

20. . COMPLAINTS

If you have privacy concerns, contact us first.
If concerns remain unresolved, users may seek guidance through applicable Australian privacy channels.