PRIVACY POLICY
Operated by Nicole Tewierik Coaching Pty Ltd (ABN 83 604 433 089)
Last updated: June 2026
1. Introduction
Nicole Tewierik Coaching Pty Ltd (we, us, our) operates the Leadership Habit Tracker platform (the Platform). We are committed to handling personal information responsibly and in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
This Privacy Policy explains what personal information we collect, why we collect it, how we hold and use it, who we disclose it to, and how you can access, correct or request deletion of your personal information.
The Platform is provided to individuals through their organisation, which holds a licence with us under a separate services agreement. References to "your organisation" in this Policy mean the organisation through which you access the Platform.
2. What we collect
We collect the following kinds of personal information:
Account information.
Your name, work email address, the role assigned to you on the Platform, and your organisation. Where your organisation uses organisational units, your placement within its structure may also be recorded.
Program activity.
The behavioural commitments you nominate, the reflections you record, and your interactions with reminders and prompts. Reflections are written in your own words and may contain information about your work experiences.
Technical information.
Information generated automatically when you use the Platform, such as login times and essential session data needed to keep you securely signed in.
We collect this information directly from you when you use the Platform, and from your organisation when it sets up your account. We do not collect more information than we need to operate the Platform.
We do not knowingly collect sensitive information as defined in the Privacy Act. We encourage you not to include health information or other sensitive information in your reflections.
3. Why we collect it
We collect, hold and use personal information to:
(a) provide you with access to the Platform and operate your account;
(b) support the core function of the Platform: recording commitments, delivering reinforcement prompts, and capturing reflections as part of your organisation's leadership development program;
(c) produce aggregated, de-identified insights for your organisation, such as which capability areas are most frequently selected across a cohort;
(d) maintain the security and integrity of the Platform;
(e) communicate with you about the Platform, including service notifications and reminders; and
(f) comply with our legal obligations.
We do not use your personal information for advertising. We do not sell personal information to anyone.
4. Who can see your information
Access to information on the Platform is restricted by role and enforced at the database level:
You can see your own commitments, reminders and reflection history.
Your organisation's administrators can see participant and cohort administration details and aggregated, theme-level insights, such as which parts of a capability framework are most referenced across the organisation. Administrators do not have access to your individual commitments or the content of your individual reflections.
Facilitator-facing summaries present patterns at the cohort level. They are designed to show where a group is progressing and where it is not, rather than to report on individuals.
We maintain the Platform as its operator and can access data where necessary to provide, support and secure the service. We access individual records only where required for support, security or legal reasons.
Data belonging to one organisation is structurally separated from data belonging to any other organisation. No organisation can access another organisation's data.
5. Disclosure and overseas handling
We disclose personal information only to the service providers we use to operate the Platform, and only to the extent necessary to provide the service. These providers deliver database hosting, application hosting, email delivery and, where in use, artificial intelligence processing.
Our primary data storage is located in Singapore. Some service providers process information in the United States. By using the Platform, you acknowledge that your personal information may be processed in these countries. We take reasonable steps to ensure that our service providers handle personal information in a manner consistent with the Australian Privacy Principles, including through contractual protections and the selection of reputable providers.
We do not otherwise disclose your personal information to third parties unless you consent, or the disclosure is required or authorised by law.
6. Artificial intelligence
The Platform may use artificial intelligence services to generate personalised reinforcement prompts and aggregated cohort summaries. Where these features are in use:
(a) the information processed is limited to what is needed to generate the relevant prompt or summary;
(b) your data is not used to train AI models; and
(c) cohort summaries are generated at an aggregated level and are designed to surface group patterns, not to evaluate individuals.
If the scope of AI features changes in a way that affects how personal information is handled, we will update this Policy before the change takes effect.
7. How we protect your information
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. These steps include encryption of data in transit and at rest, role-based access controls, database-level separation of each organisation's data, and restriction of administrative access to authorised personnel only.
No method of transmission or storage is completely secure. If a data breach occurs that is likely to result in serious harm, we will assess and respond to it in accordance with the Notifiable Data Breaches scheme under the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner where required.
8. Retention and deletion
We retain personal information for as long as it is needed to provide the Platform to your organisation.
While your organisation's licence is active.
Your information is retained so that your commitment and reflection history remains available to you and so that aggregated insights remain accurate for your organisation. If your account is deactivated, your information is no longer individually visible on the Platform, but it may continue to contribute to aggregated, de-identified insights unless deletion is requested.
When your organisation's licence ends.
We retain the organisation's data for 90 days following termination so that the organisation may request an export. After that period, personal information is deleted or de-identified.
Deletion on request.
You may request the deletion of your personal information at any time. Requests are ordinarily made through your organisation's administrator, but you may also contact us directly at [email protected]. When personal information is deleted, it is removed from the Platform. Aggregated statistics that no longer identify any individual may be retained, as de-identified information is not personal information under the Privacy Act.
We honour valid deletion requests within a reasonable period and confirm completion to the requesting party.
9. Cookies and analytics
The Platform uses only the cookies and similar technologies that are necessary to operate the service, such as keeping you securely signed in. We do not currently run third-party analytics or advertising trackers on the Platform. If analytics are introduced in the future, this Policy will be updated to describe them before they take effect.
10. Access and correction
You may request access to the personal information we hold about you, and request correction of information that is inaccurate, out of date or incomplete. Most of your information is directly visible to you within the Platform. For anything you cannot access or correct yourself, contact us at [email protected] and we will respond within a reasonable period. If we refuse a request, we will explain why and how you may complain about the refusal.
11. Complaints
If you have a concern about how we have handled your personal information, please contact us first at [email protected]. We will acknowledge your complaint promptly, investigate it, and respond to you within a reasonable period.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by phone on 1300 363 992.
12. Changes to this Policy
We may update this Privacy Policy from time to time. The current version will always be available on this page, with the date of the most recent update shown at the top. If we make a material change to how we handle personal information, we will give notice through the Platform or by email before the change takes effect.
13. Contact
Privacy enquiries can be directed to:
Nicole Tewierik Coaching Pty Ltd
ABN 83 604 433 089
Email: [email protected]
