Privacy Policy

PB Collective is a technology platform, not a direct provider of coaching services. Coaches available through the platform are independent service providers.

By using PB Collective:

• you engage directly with coaches
• coaches may access and process your data to deliver services
• PB Collective provides the infrastructure that enables this interaction

PB Collective does not supervise, control, or guarantee the quality, accuracy, or outcomes of any coaching services. You acknowledge that any actions you take based on coaching or information obtained through the platform are at your own risk.

We collect the following categories of information to operate the platform and deliver services.

General Personal Information

• Name, email address, and phone number
• Account login credentials
• Payment and billing information
• Device information and app interaction data
• Log and analytics data
• User-generated content, including messages, check-in responses, and feedback
• Data from connected third-party services, wearables, or referrals

Sensitive Information

The following categories are sensitive information as defined under the Privacy Act 1988 (Cth), s 6, and are subject to additional protections under the Australian Privacy Principles:

• Training data, including workouts and performance metrics
• Recovery and readiness data, including fatigue, soreness, and pulse data
• Injury and rehabilitation information
• Body composition and physical metrics
• Nutrition and lifestyle data

We collect sensitive information only where you have given express consent at onboarding, and only for the purposes described in this policy. See Section 5 for how we handle consent and how you can withdraw it.

How We Collect This Information

• Direct input during onboarding and platform use
• Communications between you and coaches
• Connected third-party services and wearables
• Cookies and analytics tools

We collect information through:

• Direct user input during onboarding and usage
• Interactions within the platform
• Communications with coaches
• Connected third-party services
• Cookies and analytics tools

We use your information for the following purposes.

Platform Operation

Delivering and operating the PB Collective platform, enabling coaching services, facilitating communication between users and coaches, and processing payments and subscriptions.

Service Delivery

Providing progress tracking, readiness indicators, and fatigue metrics based on data you and your coaches input. These outputs are informational only and do not replace your coach's judgment or any professional health advice.

Automated Processing

We use automated systems to generate readiness scores, fatigue indicators, and progress metrics from your health and performance data. These outputs do not produce legal or similarly significant effects, and no decisions about your coaching services are made by automated systems alone. Your coach and you retain final judgment on all training and health decisions.

Platform Improvement

Improving platform functionality and user experience based on usage data and analytics.

Communications

Sending service-related notifications, including workout reminders, booking updates, and account or billing information.

Legal Compliance

Meeting obligations under applicable Australian law.

De-identified Data

We may use de-identified and aggregated data for analytics, product development, and performance benchmarking. This data is processed in a form that cannot be used to identify you. Raw health data is not provided to any third party in identifiable form for these purposes.

Before any data is used for analytics, product development, or performance benchmarking, it is de-identified in accordance with the OAIC's guidance on de-identification of data. This process removes direct identifiers and reduces the risk of re-identification to a level we consider acceptable given the sensitivity of the data involved.

We collect sensitive information, as defined under the Privacy Act 1988 (Cth), s 6, only where you have given express consent. This consent is obtained through a dedicated consent step during onboarding, separate from your acceptance of our Terms of Service. You will be asked to actively confirm consent for each category of sensitive information before that data is collected or shared with any coach.

What Your Consent Covers

Your consent authorises us to:

• collect and store the sensitive information categories listed in Section 2
• share relevant sensitive information with coaches you engage through the platform
• process that information to generate readiness scores, fatigue indicators, and progress metrics as described in Section 4
• use de-identified and aggregated forms of that information for platform analytics and development

What Your Consent Does Not Cover

Sensitive information is not shared with third parties outside of the purposes listed above. Coaches may not use your sensitive information outside the platform without separate, explicit consent from you. This information does not constitute medical advice, diagnosis, or treatment. Where health concerns arise, you should seek qualified healthcare advice.

Withdrawing Consent

You may withdraw consent for the collection or use of sensitive information at any time through your account settings. Withdrawing consent for specific data categories will have the following effects:

• Health and performance data — coaches will lose access to historical and ongoing metrics for that category.
• Readiness and fatigue data — automated indicators will no longer be generated.
• Injury and rehabilitation data — this information will no longer be visible to any coach on the platform.

Coaches

Coaches you engage through the platform will have access to the personal and sensitive information necessary to deliver their services. Where you engage multiple coaches, relevant information may be shared across those coaches to enable coordinated support. Coaches are permitted to access your information only for the purpose of delivering services to you and may not use it outside the platform without your separate, explicit consent.

Third-party Service Providers

We share information with third-party providers who support platform operations. Each provider receives only the information necessary to perform their specific function. The categories of providers we use are:

• Payment processors, for billing and subscription management.
• Cloud hosting providers, for data storage and platform infrastructure.
• Analytics and monitoring services, for platform performance and error tracking.
• Communication and messaging infrastructure, for in-app messaging delivery.
• Wearable and integration partners, for data ingested from connected devices.

Providers handling sensitive health and performance data are required to handle that data in accordance with applicable privacy obligations. Raw, identifiable health data is not shared with analytics or benchmarking providers.

Legal Requirements

We may disclose your information where required by Australian law or by a regulatory authority. Where permitted, we will notify you before such disclosure occurs.

What We Do Not Do

User-Generated Content

You are responsible for content you upload to the platform, including messages, images, and videos. By uploading content, you grant Glass House Solutions Pty Ltd a limited right to store, process, and display that content for platform functionality. We reserve the right to remove content that violates our Terms of Service.

Some third-party providers may store or process data outside Australia. We take reasonable steps to ensure these providers comply with privacy obligations equivalent to those required under the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

We take reasonable steps to protect your information, including:

• Encryption of data in transit and at rest
• Role-based access controls (client, coach, admin)
• Secure cloud infrastructure
• Monitoring and access logging

We implement industry-standard security measures to protect your data, including encryption in transit and at rest, secure authentication controls, and role-based access permissions. Access to personal information is restricted to authorised personnel and service providers who require it to operate the platform.

We continuously monitor our systems to detect and prevent unauthorised access.

We retain different categories of information for different periods, set out below. Where no specific period is listed, we retain information for as long as is necessary to fulfil the purpose for which it was collected, after which it is deleted or de-identified.

Retention Periods

• Account data: retained for the duration of your account. Following account closure, account data is deleted within a maximum of 90 days, except where retention is required for legal or dispute resolution purposes.
• Health and performance data: retained for the duration of your account and for a maximum of 2 years following account closure, to support continuity of care if you re-engage with the platform or a coach. After this period, data is deleted or de-identified.
• Messages and coaching content: retained for the duration of your account and for a maximum of 12 months following account closure, to maintain coaching context and support dispute resolution where required. After this period, messages and associated media are deleted.
• Payment and financial records: retained for 7 years following the transaction date, in accordance with the requirements of the Corporations Act 2001 (Cth) and the Australian Taxation Office.
• Analytics and usage data: retained for a maximum of 12 months in identifiable form, after which it is de-identified or deleted.

Deletion Requests

You may request deletion of your account and associated data at any time through your account settings or by contacting us using the details in Section 15. We will action deletion requests within 30 days, subject to any legal obligation to retain specific records. Where we are required to retain data beyond your request, we will inform you of the reason and the applicable retention period.

You have the right to:

• access your personal information
• request corrections
• request deletion (where applicable)
• control which coaches can access your data
• opt out of non-essential communications

Requests can be made via the contact details in Section 15.

We may send you:

• service notifications (workouts, bookings, messages)
• progress and check-in reminders
• account and billing updates

You can manage notification preferences within the app. All commercial electronic messages include an unsubscribe facility in accordance with the Spam Act 2003 (Cth).

PB Collective is intended for users aged 18 and over. We do not knowingly collect personal or sensitive information from individuals under 18.

Age Verification

We do not currently operate a technical age verification mechanism. Users are required to confirm their age during account creation. If we become aware that a user is under 18, we will suspend the account and delete associated data promptly.

If a Minor Has Accessed the Platform

If you are a parent or guardian and believe your child has created an account or provided personal information through the platform, contact us using the details in Section 15. We will investigate and, where confirmed, delete the account and associated data within 30 days.

Future Controls

We are reviewing options to implement age verification controls and will update this policy when those controls are in place.

PB Collective may integrate with or link to third-party services. We are not responsible for the privacy practices of those services. We encourage you to review the privacy policies of any third-party service you connect to the platform.

We may update this Privacy Policy from time to time. Updates will be made available within the app or via our website. Where a change is material, we will notify you by email to the address on your account before the change takes effect.

If you have questions or requests regarding your personal information or this policy, contact our Privacy Officer:

You also have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) if you believe we have handled your personal information in a way that does not comply with the Privacy Act 1988 (Cth) or the Australian Privacy Principles. Before contacting the OAIC, we encourage you to contact us directly so we can attempt to resolve your concern.

Office of the Australian Information Commissioner

Personal Best Collective is a product of Glass House Solutions Pty Ltd.