PRIVACY POLICY

Empowerdance Pty Ltd is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

WHAT IS PERSONAL INFORMATION AND WHY DO WE COLLECT IT?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes names, addresses, email addresses, phone numbers, and details about students such as date of birth and emergency contact information.

This Personal Information is obtained in many ways including lead generation forms on Meta (Facebook and Instagram), forms on our website, telephone, email, enrolment and booking forms, and cookies on our website and from third parties. We don’t guarantee website links or policy of authorised third parties.

We collect your Personal Information for the primary purpose of providing our dance classes and related services to you, communicating with students and parents, and marketing, including running and measuring the performance of our advertising campaigns on Meta (Facebook and Instagram). This includes using your details to build custom audiences for retargeting and to exclude existing students, parents or leads from particular campaigns. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists or ask to be excluded from our advertising audiences at any time by contacting us in writing.

When we collect Personal Information, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Some of our services are provided to children. Where a student is under 18, we generally collect that student’s Personal Information from a parent or guardian who enquires or enrols on the student’s behalf. By submitting a student’s details, a parent or guardian confirms they have authority to provide that information to us.

SENSITIVE INFORMATION

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• For the primary purpose for which it was obtained

• For a secondary purpose that is directly related to the primary purpose

• With your consent; or where required or authorised by law.

THIRD PARTIES

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

DISCLOSURE OF PERSONAL INFORMATION

Your Personal Information may be disclosed in a number of circumstances including the following:

• Third parties where you consent to the use or disclosure; and

• Meta Platforms, Inc. (Facebook and Instagram), for the purposes of running and measuring our advertising, including creating custom audiences from our customer and lead lists for retargeting, excluding existing students, parents or leads from particular campaigns, and receiving aggregated campaign performance and analysis data; and

• Our website, hosting, email and CRM service providers who help us run our business; and

• Where required or authorised by law.

We do not sell Personal Information. Some of our service providers, including Meta and other cloud, hosting, CRM and analytics providers, may store or process Personal Information on servers located outside Australia, including in the United States. Before disclosing Personal Information overseas, we take reasonable steps to ensure the recipient handles it consistently Page 3 with the Australian Privacy Principles. By providing your Personal Information to us, you consent to this overseas disclosure.

SECURITY OF PERSONAL INFORMATION

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

ACCESS TO YOUR PERSONAL INFORMATION

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Empowerdance Pty Ltd will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information, we may require identification from you before releasing the requested information.

MAINTAINING THE QUALITY OF YOUR PERSONAL INFORMATION

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

POLICY UPDATES

This Policy may change from time to time and is available on our website.

PRIVACY POLICY COMPLAINTS AND ENQUIRIES

If you have any queries or complaints about our Privacy Policy, please contact us at the details below. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

Empowerdance Pty Ltd | ABN: 83 166 140 405

Level One, 237 – 239 Unley Road, Malvern, SA, 5061

hello@empowerdance.com.au | (08) 8352 2006