1. ABOUT THIS POLICY

OSKAYA PTY LTD ACN 663 255 721, trading as Holly McKee Elliott Coaching ("we", "us", "our"), is committed to protecting your personal information and handling it responsibly and transparently.

This Privacy Policy explains how we collect, use, hold, disclose, and protect your personal information. It applies to all Services offered under the Holly McKee Elliott Coaching brand, including coaching programs, workshops, events, digital educational content, and our website and platforms.

By using our website, registering for Services, or entering into a Coaching Services Agreement with us, you consent to the collection and use of your personal information as described in this Policy.

We are committed to handling personal information in accordance with the principles contained in the Privacy Act 1988 (Cth) and the Australian Privacy Principles, regardless of whether we are formally required to comply with that Act.

 

2. WHAT PERSONAL INFORMATION WE COLLECT

We collect personal information that is reasonably necessary to provide our Services. This may include:

• Full name and contact details (email address, phone number)
• Demographic information (age, location, occupation, and similar)
• Health and wellbeing information you choose to share in the context of coaching (including information about stress, mental health, lifestyle, and physical health) — this is sensitive information and is handled with additional care
• Goals, challenges, and personal development information shared during coaching sessions or in intake forms
• Payment and billing information (processed through Kajabi Payments — we do not store your full card details)
• Session notes, coaching records, and correspondence with us, including via email and WhatsApp
• Information provided when booking appointments via Calendly
• Information collected via website contact forms, landing page opt-ins, or event registrations
• AI-generated transcription notes from coaching sessions (where you have provided consent — see clause 7)
• Technical data such as IP address, browser type, and device information collected automatically when you use our website or platforms

 

3. HOW WE COLLECT PERSONAL INFORMATION

We collect personal information:

(a)  Directly from you, when you register for a program or workshop, complete a booking or checkout, fill in an intake or pre-call form, correspond with us via email or WhatsApp, participate in a coaching session, complete program exercises or worksheets, or provide a testimonial.

(b)  Automatically, through your use of our website (hosted by Kajabi) and booking platform (Calendly), which may use cookies and similar technologies to collect technical usage data.

(c)  From third-party platforms, where you engage with us via social media or other digital platforms.

 

4. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information to:

• Deliver coaching services, programs, and events you have purchased or registered for
• Communicate with you about your program, bookings, and any administrative matters
• Process payments and manage billing
• Maintain session notes and program records
• Send you relevant emails, program updates, or marketing communications where permitted by law and with your consent where required
• Improve our Services, programs, and content
• Comply with our legal obligations

We will not use your personal information for any purpose that is inconsistent with the purpose for which it was collected, unless you have provided your consent or we are required to do so by law.

 

5. DISCLOSURE OF PERSONAL INFORMATION

We do not sell your personal information to third parties.

We may disclose your personal information to:

(a)  Service providers who assist us in delivering our Services, including Kajabi (platform hosting and payment processing), Calendly (appointment booking), Google (Google Meet video conferencing and Google Gemini note-taking), ManyChat (messaging automation and subscriber communications), WhatsApp (between-session client communication), and Notion (internal records). These providers are bound by their own privacy policies and data handling obligations.

(b)  Our professional advisors, including legal, insurance, and accounting advisors, on a confidential basis.

(c)  Law enforcement, regulatory bodies, or courts where we are required to do so by law, court order, or where disclosure is necessary to respond to a serious threat to health or safety.

(d)  A supervisor, coach mentor, or professional development support where information is shared in anonymised form for the purpose of maintaining the quality and safety of coaching services.

We will take reasonable steps to ensure that any third parties to whom we disclose your personal information are bound by appropriate privacy obligations.

 

6. INTERNATIONAL DATA TRANSFERS

Some of the third-party platforms we use (including Kajabi, Calendly, Google, and WhatsApp) may store or process data on servers located outside of Australia.

By using our Services and accepting this Privacy Policy, you acknowledge that your personal information may be transferred to and stored in countries outside Australia. We take reasonable steps to ensure that overseas recipients handle your personal information in a manner consistent with the Australian Privacy Principles.

 

7. AI-ASSISTED NOTE-TAKING

With your prior consent (as outlined in your Coaching Services Agreement), we may use Google Gemini or similar AI-assisted transcription and note-taking tools during coaching sessions.

AI-generated notes are used solely to support the quality of your coaching experience and are not shared with third parties except as set out in clause 5(a) above. AI-generated notes may contain errors and are reviewed as appropriate before being relied upon. Google's own privacy policy governs the processing of data through Google Gemini.

You may withdraw your consent to AI note-taking at any time by notifying us in writing prior to a session. Withdrawal of consent will not affect sessions already conducted.

 

8. SENSITIVE INFORMATION

We recognise that much of the personal information you share in a coaching context is sensitive in nature, including information about your mental health, physical health, relationships, and personal circumstances.

We only collect sensitive information that you voluntarily provide in the context of receiving coaching Services, and only to the extent reasonably necessary to deliver those Services. We handle sensitive information with additional care and will not use or disclose it for any purpose other than delivering the Services for which it was collected, unless required by law, with your explicit consent, or where necessary to respond to a serious threat to health or safety.

 

9. STORAGE AND SECURITY

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, and disclosure.

Your information is stored across the following platforms: Kajabi (program content and payment records), Calendly (booking records), Google Workspace (session notes and correspondence), WhatsApp (between-session communications), and Notion (internal coaching records). Each platform maintains its own industry-standard security measures. Payment information is processed and held by Kajabi Payments and is not stored by us.

No data transmission over the internet is completely secure. While we take reasonable precautions, we cannot guarantee absolute security.

We retain your personal information for as long as reasonably necessary to provide our Services and meet our legal obligations, and in any event for no longer than 7 years following the conclusion of your program or last engagement with us, after which it will be securely deleted or de-identified.

 

10. ACCESS AND CORRECTION

You have the right to request access to the personal information we hold about you, and to request that we correct any information that is inaccurate, out of date, incomplete, or misleading.

To make an access or correction request, please contact us at info@oskaya.com.au. We will respond within a reasonable timeframe and in accordance with the principles of the Privacy Act 1988 (Cth).

In some circumstances we may decline a request for access — for example, where providing access would unreasonably affect the privacy of another individual, or where the information is subject to legal professional privilege. We will provide written reasons for any refusal.

 

11. COMPLAINTS

If you have a complaint about how we have handled your personal information, please contact us in the first instance at info@oskaya.com.au. We will endeavour to respond within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.

 

12. COOKIES AND WEBSITE ANALYTICS

Our website (hosted on Kajabi) may use cookies and similar tracking technologies to improve your experience and analyse website traffic.

We may use analytics and advertising tools from time to time, including tools provided by Google, Meta, TikTok, and other platforms. Details of the tools currently in use are available upon request at info@oskaya.com.au.

You can control cookie settings through your browser preferences. Disabling cookies may affect the functionality of some parts of our website.

 

13. MARKETING COMMUNICATIONS

Where permitted by law and with your consent where required, we may send you marketing emails about our Services, programs, workshops, and events. You can unsubscribe from marketing communications at any time by clicking the unsubscribe link in any email, or by contacting us at info@oskaya.com.au.

We will continue to send you essential transactional communications related to your active program even if you unsubscribe from marketing communications.

 

14. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. Material changes will be communicated to active clients. The current version will always be available on our website.

The effective date at the top of this Policy indicates when it was last updated.

 

15. CONTACT US

For any privacy-related enquiries, access requests, or complaints, please contact:

Privacy Officer

OSKAYA PTY LTD trading as Holly McKee Elliott Coaching

Email: info@oskaya.com.au

Sydney, NSW, Australia