1. Overview

The Mastermind (“The Mastermind,” “we,” “us,” and “our“) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (“Privacy Policy“). This Privacy Policy describes how we collect and use your Personal Information when you visit our website at https://www.themastermind.com.au/ (the “Site“), apply for or participate in our coaching programs, attend our events, or otherwise use our products and services (collectively, the “Services“), and when you provide information to us through electronic messages, phone, or in person.

Please read this Privacy Policy to understand our policies and practices regarding your Personal Information and how we handle it. If you do not agree with our policies and practices, please do not use the Site or the Services. By accessing or using the Site or the Services, you agree and consent to this Privacy Policy.

The Mastermind may change this Privacy Policy at any time, at its discretion. Your continued use of the Site or Services after we make changes is deemed to be acceptance of, and consent to, those changes, so please check this Privacy Policy periodically for updates.

2. The Information We Collect and How We Collect It

We may collect two types of information from you: Personal Information and Non-Personal Information (collectively, “Information“).

“Personal Information” refers to data by which you may be personally identified, such as name, email address, postal address, telephone number, business name, job title, billing and payment information, and account credentials.

“Non-Personal Information” means data that is about you but does not identify you specifically. If you do nothing during your visit to our Site but browse, read pages, or view content, we will gather and store Information about your visit that does not identify you personally.

We collect Information in three ways:

Directly from you. When you apply for The Mastermind, book a sales call, register for an event, enrol in a program, subscribe to a newsletter, request information, or otherwise contact us, we ask for details such as your name, contact information, business details, goals, billing information, and account credentials in order to fulfil your request. If you submit Personal Information about other people to us (for example, team members or referrals), you are responsible for ensuring you have the authority to do so and to allow us to use that Personal Information in accordance with this Privacy Policy.

From third parties. We obtain information through partners, vendors, advertising platforms (including Meta and Google), lead generation partners, event co-hosts, referral sources, and other third parties. We take reasonable steps to confirm that information we receive from these third parties has been collected with your consent or that these parties are otherwise legally permitted to disclose your Personal Information to us. In some cases we combine Personal Information received from multiple sources, including directly from you and through your use of the Site.

Automatically as you navigate through the Site. We collect information about how you interact with the Site through cookies, pixel tags (including the Meta Pixel and Google Analytics), server logs, and similar technologies. This includes IP address, device type, browser type, operating system, referring URLs, pages visited, time spent on pages, and other usage data.

3. How We Use Your Personal Information

We use Personal Information that we collect about you, or that you provide to us, for the following purposes:

To Provide and Deliver the Services. To assess applications, deliver coaching, run events, fulfil program obligations, personalise your experience, and communicate with you about your membership or participation.

For Customer Support, Reporting, and Improvement. To respond to enquiries, provide updates about programs or events, investigate and resolve issues, analyse performance, and improve the Site and Services.

For Business Operations. To perform accounting, auditing, billing, reconciliation, and collection activities; to prevent fraud and unauthorised access; to enforce our terms; to protect our legal rights; and to meet our contractual obligations.

To Communicate With You. To send you messages about your application, membership, program, or event; to respond to requests; to provide alerts such as security updates or policy changes; and to send marketing or informational materials such as newsletters, invitations, and offers, in accordance with your communication preferences and applicable law (including the Spam Act 2003 (Cth) in Australia).

For Advertising and Marketing. To deliver and measure the effectiveness of advertising, including retargeting and lookalike audience creation on platforms such as Meta (Facebook, Instagram) and Google. We may combine Personal Information with information about advertisements you viewed to provide more relevant content and study campaign effectiveness.

For Statistical and Analytical Purposes. To compile Site statistics, understand usage patterns, and create a better overall experience.

We do not retain your Personal Information to develop, improve, or train generalised artificial intelligence or machine learning models.

4. Text Message (SMS) Communications

If you provide your mobile number and opt in to receive text messages from us, we may send transactional messages (such as appointment reminders or account notifications), informational messages, and marketing messages where you have consented to receive them. Message and data rates may apply. You can opt out of marketing SMS at any time by replying STOP to any marketing message.

We do not share your mobile number or SMS opt-in consent with third parties or affiliates for their own marketing purposes. Text messaging originator opt-in data and consent will not be shared with any third parties except the aggregators and telecommunications providers that deliver the messages on our behalf.

5. How We Protect Your Information

We maintain reasonable administrative, technical, and organisational security measures designed to protect your Personal Information against risks such as loss, destruction, and unauthorised or unlawful access, alteration, use, or disclosure. We require our suppliers and vendors to apply similar protections when they access or use Personal Information we share with them.

No technology, data transmission, or system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your password has been compromised), please notify us immediately using the details in “How to Contact Us” below.

6. How Long We Retain Your Personal Information

We retain your Personal Information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements, and for other purposes described in this Privacy Policy. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and applicable legal requirements. In some circumstances we will anonymise your Personal Information (so that it can no longer be associated with you), in which case we may use this information without further notice to you.

7. When We Share Your Information

We work with affiliates, suppliers, and business partners to provide the Services. When we share your Personal Information with these parties, we put in place appropriate measures to limit the use of your information to purposes consistent with this Privacy Policy, and require appropriate confidentiality and security measures.

We may disclose Personal Information:

With Affiliates. Including other businesses operated by our founder, where doing so is consistent with the purposes described in this Privacy Policy.

With Service Providers. Our authorised vendors and suppliers require Personal Information to provide services we have contracted for, such as website hosting, CRM and marketing automation platforms, email and SMS delivery, payment processing, analytics, accounting, IT services, event delivery, and customer support. Our contracts with these providers include provisions to protect your Personal Information and limit its use.

With Partners. We occasionally work with third parties who are not vendors but are working with us to offer joint events, promotions, or products. In these cases, additional terms or privacy notices may apply.

For Advertising and Marketing. With advertising platforms such as Meta and Google, to deliver and measure the effectiveness of advertising and to enable personalised content and ads.

In a Business Transaction. As part of a contemplated or actual corporate transaction such as a reorganisation, merger, sale, joint venture, assignment, or transfer of all or part of our business or assets (including in connection with insolvency proceedings).

For Legal Reasons. When required by law or to respond to legal process; to protect our clients, members, employees, or the public; to maintain the security and integrity of the Site; to investigate fraud or misconduct; and to protect our legal rights.

With Your Consent. To any other person or entity where you consent to the disclosure.

We do not sell your Personal Information for monetary compensation. We also share non-personally identifiable information, such as anonymised or aggregated information, with suppliers and partners for analytics, research, and business development purposes.

8. Cookies and Similar Technologies

We use cookies, pixel tags (including the Meta Pixel and Google Analytics), local storage, and similar technologies to operate the Site, analyse usage, remember your preferences, personalise content, and deliver and measure advertising. You can manage cookies through your browser settings. Disabling cookies may affect the functionality of the Site.

At this time, the Site does not respond to “Do Not Track” signals from browsers.

9. Information From Children

We do not knowingly collect, use, or disclose Personal Information from children under the age of 16 (or the equivalent minimum age in the relevant jurisdiction, such as 13 in the United States under the Children’s Online Privacy Protection Act). If we learn that we have collected the Personal Information of a child under the applicable age, we will take steps to delete the information as soon as possible. If you believe a child has provided Personal Information to us, please contact us using the details in “How to Contact Us.”

10. Links to Other Websites and Services

The Site may contain links to websites and services operated by third parties. We are not responsible for the privacy practices of those third parties. This Privacy Policy does not apply to, and we are not responsible for, the policies and practices of third parties or other organisations not operating on our behalf, including any social media platforms, operating system providers, or device manufacturers.

11. Your Rights and Choices

You have certain rights regarding your Personal Information. These rights vary depending on where you live.

11.1 Australian Residents

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), you have the right to:

• Access the Personal Information we hold about you
• Request correction of inaccurate or out-of-date Personal Information
• Opt out of receiving direct marketing communications
• Make a complaint about how we have handled your Personal Information

If you are not satisfied with our response to a complaint, you may contact the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/ or on 1300 363 992.

11.2 European Economic Area, United Kingdom, and Switzerland

If you are in the EEA, UK, or Switzerland, you may have additional rights under the GDPR, UK GDPR, or Swiss data protection law, including the right to:

• Access your Personal Information
• Request correction or deletion
• Restrict or object to processing
• Request portability of your Personal Information
• Withdraw consent where processing is based on consent

Our legal basis for collecting and using Personal Information will depend on the Personal Information concerned and the specific context. Generally, we process Personal Information where we have your consent, where we need the information to perform a contract with you, where we have a legal obligation to do so, or where the processing is in our legitimate interests (such as direct marketing, product improvement, fraud prevention, or information security) and not overridden by your data protection interests.

Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, or processing carried out on other legal bases.

If you believe we are using your Personal Information in a way that is inconsistent with this Privacy Policy, you may contact your local data protection authority.

11.3 California Residents

Under the California Consumer Privacy Act (“CCPA“), as amended, California residents have the right to:

• Be notified about the collection, use, disclosure, sale, or sharing of their Personal Information
• Request access to, deletion of, or correction of their Personal Information
• Opt out of the “sale” or “sharing” (cross-contextual behavioural advertising) of Personal Information
• Limit the use or disclosure of Sensitive Personal Information
• Not be discriminated against for exercising these rights

The Mastermind does not sell your Personal Information for monetary compensation. If you wish to opt out of cross-contextual targeted advertising (“sharing” under the CCPA), please contact us using the details in “How to Contact Us” or use the opt-out mechanism provided on the Site.

You can designate an authorised agent to make a request on your behalf. We may ask you to verify your identity or that you provided the agent with signed permission before responding.

11.4 Other U.S. States (Colorado, Connecticut, Utah, Virginia, and others)

If you are a resident of Colorado, Connecticut, Utah, Virginia, or another U.S. state with a comprehensive consumer privacy law, you may have rights similar to those described above, including the right to access, correct, delete, or obtain a portable copy of your Personal Information, and to opt out of targeted advertising, sale, or certain profiling.

You can exercise these rights by contacting us using the details in “How to Contact Us.” If we decline to take action, you have the right to appeal by contacting us again at the same address.

11.5 How to Exercise Your Rights

You can exercise any of the rights above by contacting us using the details in “How to Contact Us.” We may ask you to verify your identity before responding, and the information we request will depend on the sensitivity of the Personal Information and your prior interactions with us. If we deny your request, we will explain why.

Please note that we may still need to retain certain Personal Information for recordkeeping purposes, to complete any transactions that you began prior to your request, to comply with applicable law, or for other purposes permitted by law.

12. Marketing Communications and Your Choices

You may unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link at the bottom of any marketing email, or by contacting us. You may opt out of marketing SMS by replying STOP to any marketing text message. Please note that even if you opt out of marketing communications, we may still send you transactional or service-related communications (for example, about your application, membership, programs, events, or account).

13. International Data Transfers

The Mastermind operates in Australia and works with service providers and partners in the United States and other countries. If you access the Site or use the Services from outside Australia, your Personal Information may be transferred to, stored, and processed in Australia, the United States, or other countries where our service providers operate.

Where we transfer Personal Information internationally, we take reasonable steps to ensure that the transfer complies with applicable data protection laws and that the information continues to be protected to a standard consistent with this Privacy Policy.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top of this Privacy Policy indicates when it was most recently revised. Your continued use of the Site or Services after any changes constitutes your acceptance of the revised Privacy Policy. For material changes, we will provide additional notice where required by law.

15. How to Contact Us

If you have questions about this Privacy Policy, or if you want to exercise any of your rights, please contact us:

The Mastermind Level 11, 458 Brunswick Street Fortitude Valley QLD 4006 Australia

Phone (Australia): 1300 680 223 Phone (United States): 361 494 0622 Email:   privacy@themastermind.com.au

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