PRIVACY POLICY

1. ABOUT THIS POLICY

This Privacy Policy applies to Barnard Family Trust ABN 38709610632, trading as The Success Method™ (we, us, our), located at 2/10 Lake Kawana Blvd, Birtinya QLD 4575, Australia.

This Policy governs all personal information collected through:

• our website at www.thesuccessmethod.co (Website)

• our program, including The Success Method™ Membership, The LaunchPad™ Program (course)

• our community platforms, including our private Facebook group

• direct communications, enquiries, and purchases

We may update this Policy at any time by publishing a revised version on our Website. The date of the most recent revision is shown at the top of this document. Your continued use of our Website or Services following any update constitutes your acceptance of the revised Policy.

For all privacy-related enquiries, contact us at: support@thesuccessmethod.co

2. WHAT PERSONAL INFORMATION WE COLLECT

Personal information means any information that identifies you or could reasonably identify you, either directly or indirectly. We collect the following categories of personal information:

2.1 Information You Provide Directly

• Identity information: full name

• Contact information: email address, phone number, postal address

• Payment information: billing details, payment method (note: full card details are processed by our third-party payment providers and are not stored by us)

• Business information: business name, industry, goals, and experience level

• Communications: enquiries, feedback, survey responses, and support requests

• Community content: posts, comments, and interactions in our private community spaces

2.2 Information Collected Automatically

• Technical data: IP address, browser type and version, operating system, device type

• Usage data: pages visited, time on site, referring URLs, click behaviour

• Cookie data: session cookies, analytics cookies, and advertising cookies (see Clause 11)

2.3 Information From Third Parties

We may receive personal information about you from third-party sources including payment processors, advertising platforms (such as Meta and Google), and referral partners. Where we receive your information from a third party, we will handle it in accordance with this Policy.

3. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information:

• when you register for, or purchase, any of our programs or membership

• when you submit an enquiry or contact us via the Website, email, or social media

• when you participate in coaching sessions, group calls, or community platforms

• when you complete surveys, provide testimonials, or engage with our marketing

• automatically when you visit our Website through cookies and tracking technologies

• from third-party platforms when you interact with our advertising or content

By providing us with personal information, you consent to its collection and use in accordance with this Policy. Where we rely on consent as a lawful basis for processing, you may withdraw consent at any time by contacting us, though this will not affect the lawfulness of prior processing.

4. HOW WE USE YOUR PERSONAL INFORMATION

We use personal information only for lawful purposes and only to the extent necessary for those purposes.

We use your personal information to:

deliver and administer our programs, membership, and services

1. process payments and manage your account

2. communicate with you about your membership, program access, or enquiries

3. send you program updates, resources, and relevant information

4. send you marketing communications about our products and services, where you have opted in or

5. where permitted by law

6. improve and develop our Website, programs, and services

7. conduct research, analysis, and business reporting

8. comply with our legal obligations and enforce our Terms and Conditions

9. investigate complaints and resolve disputes

10. protect our rights, property, and the safety of our members and team

We will not use your personal information for any purpose that is incompatible with the purpose for which it was collected without your prior consent.

NOTE:

You may opt out of marketing communications at any time by clicking 'Unsubscribe' in any email or by contacting us at support@thesuccessmethod.co. Opting out of marketing does not affect communications necessary for service delivery.

5. LEGAL BASIS FOR PROCESSING (GDPR)

Where the GDPR applies to our processing of your personal information (for example, if you are located in the European Union or European Economic Area), we process your personal information on the following lawful bases:

• Contract: processing is necessary to perform our contract with you (e.g. delivering your program or membership)

• Consent: where you have given us clear, informed consent (e.g. for marketing communications)

• Legitimate Interests: where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights (e.g. improving our services, fraud prevention)

• Legal Obligation: where processing is required to comply with a legal or regulatory obligation

Where we rely on consent as our lawful basis, you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. DISCLOSURE OF YOUR PERSONAL INFORMATION

We do not sell, rent, or trade your personal information to third parties.

We may disclose your personal information in the following limited circumstances:

6.1 Service Providers and Contractors

We may share your personal information with trusted third-party service providers who assist us in operating our business, including:

• payment processors (e.g. Stripe, PayPal, or others as applicable)

• our online learning platform (Systeme.io and others as applicable)

• email marketing and CRM platforms

• cloud hosting and website infrastructure providers

• analytics and advertising platforms (e.g. Google Analytics, Meta Ads)

All service providers are required to handle your personal information in a manner consistent with this Policy and applicable privacy laws. We do not authorise service providers to use or disclose your personal information except as necessary to perform their services for us.

6.2 Legal and Regulatory Disclosure

We may disclose your personal information where required or permitted by law, including:

• in response to a court order, subpoena, warrant, or lawful request from a government authority or law enforcement agency

• where we believe disclosure is necessary to protect the rights, property, or safety of The Success Method™, our members, or the public

• in connection with legal proceedings or the enforcement of our Terms and Conditions

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or change of control of our business, your personal information may be transferred to the acquiring entity as part of that transaction. We will take reasonable steps to ensure the acquiring entity is bound by privacy obligations at least equivalent to those in this Policy. We will notify you of any such transfer by updating this Policy or by direct communication where required by law.

7. INTERNATIONAL DATA TRANSFERS

The Success Method™ operates mainly in Australia.

However, some of our service providers and technology platforms are located overseas, including in the United States and other countries. As a result, your personal information may be stored, processed, or transferred to countries outside Australia.

Where personal information is transferred internationally, we take reasonable steps to ensure it is protected by:

• contractual data protection obligations (including standard contractual clauses approved by the European Commission, where applicable)

• ensuring recipients are located in countries with privacy laws that provide comparable protection to the Australian Privacy Principles

• binding corporate rules or other approved transfer mechanisms under the GDPR, where applicable

By using our Website or Services, you consent to the transfer of your personal information to countries outside Australia as described in this Policy.

8. SECURITY OF YOUR PERSONAL INFORMATION

We take the security of your personal information seriously. We implement appropriate physical, technical, and administrative safeguards designed to protect your personal information from unauthorised access, use, disclosure, alteration, or destruction.

These measures include:

• secure SSL/TLS encryption for data transmitted via our Website

• access controls limiting personal information to authorised personnel only

• engagement of data processors who maintain adequate technical and organisational security measures

• regular review of our security practices and procedures

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. You transmit information to us at your own risk. We will notify you and any applicable regulator of a data breach in accordance with our obligations under the Privacy Act 1988 (Cth) (Notifiable Data Breaches scheme) and, where applicable, the GDPR.

9. RETENTION OF YOUR PERSONAL INFORMATION

We retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

In determining the appropriate retention period, we consider:

• the nature and sensitivity of the personal information

• the purposes for which it was collected and our ability to achieve those purposes with less data

• applicable legal and regulatory obligations, including tax and financial record-keeping requirements

• the risk of harm from unauthorised use or disclosure

When personal information is no longer required, we will securely delete or de-identify it. If you request deletion of your personal information, we will action your request subject to any overriding legal obligations we may

have to retain it.

10. YOUR PRIVACY RIGHTS

Subject to applicable law, you have the following rights in relation to your personal information held by us:

10.1 Australian Privacy Rights (Privacy Act 1988)

• Access: you may request a copy of the personal information we hold about you

• Correction: you may request that we correct personal information that is inaccurate, incomplete, or out of date

• Complaints: you may lodge a complaint with us or with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au

10.2 GDPR Rights (EU/EEA Residents)

If you are located in the EU or EEA, you have additional rights under the GDPR:

1. the right to be informed about how your personal information is used

2. the right to access your personal information (free of charge)

3. the right to rectification of inaccurate or incomplete personal information

4. the right to erasure (right to be forgotten)

5. the right to restrict processing of your personal information

6. the right to data portability

7. the right to object to processing based on legitimate interests or for direct marketing

8. the right not to be subject to solely automated decision-making, including profiling, that produces legal or similarly significant effects

To exercise any of your rights, please contact us at support@thesuccessmethod.co. We may require verification of your identity before processing any request. We will respond to valid requests within 30 days, or within the timeframe required by applicable law.

We reserve the right to decline requests that are manifestly unfounded, excessive, or where an exemption applies under the Privacy Act 1988 (Cth) or the GDPR.

11. COOKIES AND TRACKING TECHNOLOGIES

Our Website uses cookies and similar tracking technologies to enhance your browsing experience, analyse website traffic, and deliver relevant advertising.

11.1 What Are Cookies

Cookies are small text files placed on your device by a website. They allow the website to recognise your device and store certain information about your preferences or actions. Cookies are not malicious programs and cannot access other information on your device.

11.2 Types of Cookies We Use

• Essential cookies: necessary for the Website to function correctly; these cannot be disabled

• Analytics cookies: used to understand how visitors interact with the Website (e.g. Google Analytics)

• Marketing and advertising cookies: used to deliver targeted advertising through third-party services (e.g. Google Ads, Meta Pixel)

• Functional cookies: used to remember your preferences and improve your experience

11.3 Managing Cookies

You may control and disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website. For more information about managing cookies, visit www.allaboutcookies.org.

Where required by law, we will seek your consent before placing non-essential cookies on your device.

12. THIRD PARTY WEBSITES

Our Website may contain links to third-party websites.

These links are provided for your convenience only. The Success Method™ has no control over, and accepts no responsibility for, the privacy practices or content of any third-party website. We encourage you to review the privacy policy of any third-party website you visit.

The inclusion of a link does not constitute our endorsement, sponsorship, or approval of that website.

13. CHILDREN'S PRIVACY

Our Website and Services are not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. If you are under 18, you must not use our Website or Services without the consent of a parent or legal guardian.

If we become aware that we have inadvertently collected personal information from a person under 18 without appropriate consent, we will take prompt steps to delete that information. If you believe we have collected personal information from a minor, please contact us immediately at support@thesuccessmethod.co.

In addition, consistent with GDPR requirements, we will not knowingly collect or process personal information from any individual under the age of 16 without verifiable parental or guardian consent.

14. PRIVACY COMPLAINTS

If you have a concern or complaint about the way we have handled your personal information, please contact us in the first instance so we can attempt to resolve the matter directly.

To lodge a complaint:

• Email: support@thesuccessmethod.co

• Post: 2/10 Lake Kawana Blvd, Birtinya QLD 4575, Australia

We will acknowledge receipt of your complaint within five (5) business days and aim to resolve all complaints within thirty (30) days. If your complaint involves a complex matter, we will notify you of the extended timeframe required.

If you are not satisfied with our response, you may escalate your complaint to:

• Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au | 1300 363 992

• EU residents: your local Data Protection Authority (DPA)

15. CONTACT DETAILS AND DATA CONTROLLER INFORMATION

Business Name:

Barnard Family Trust t/a The Success Method™

Privacy Contact:

support@thesuccessmethod.co

Address:

2/10 Lake Kawana Blvd, Birtinya QLD 4575, Australia

Website:

www.thesuccessmethod.co

GDPR:

For the purposes of the GDPR, Barnard Family Trust t/a The Success Method™ acts as a Data Controller in respect of personal information collected directly from you, and as a Data Processor in respect of personal information processed on behalf of others. Where required, a Data Protection Officer or equivalent contact can be reached via the email address above.

16. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time.

Any changes will be effective immediately upon publication of the updated Policy on our Website. The date of the most recent update is displayed at the top of this document.

We encourage you to review this Policy periodically. Where required by law, we will notify you of material changes by direct communication or by a prominent notice on our Website.