Privacy Policy

Glow Up Hub, operated by K&L Collective Pty Ltd (ACN 699 071 746) ("we", "us", "our"), is committed to protecting the privacy of our customers and website visitors. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

By using our Platform or website, you consent to the collection and use of your personal information as described in this Privacy Policy. If you do not agree, please do not use our services.

1. Who This Policy Applies To

This Privacy Policy applies to:

• Customers who subscribe to and use the Glow Up Hub platform;
• Staff Users who access the platform on behalf of a Customer;
• visitors to our website at glowuphub.com.au; and
• any person who contacts us via our website enquiry form or by email.

2. What Personal Information We Collect

2.1 Information You Provide to Us

We collect personal information that you provide directly to us, including:

• name and email address when you create an account or contact us via our website enquiry form;
• business name, ABN, and contact details when setting up a Customer account;
• billing information including payment card details, which are processed and stored by our payment provider Stripe and are not held by us directly;
• staff names and email addresses added by a Customer to their account as Staff Users; and
• any other information you voluntarily provide when communicating with us.

2.2 Information Collected Automatically

When you visit our website or use the Platform, we may automatically collect:

• IP address and device information;
• browser type and operating system;
• pages visited and time spent on our website;
• referring URLs; and
• usage data and interactions with the Platform.

This information is collected using cookies and analytics tools including Google Analytics. Please see our Cookie Policy section (clause 8) for more information.

2.3 What We Do Not Collect

We do not collect personal information about the end clients of our Customers. Content uploaded by Customers to the Platform, such as business policies, SOPs, and training materials, may contain references to business processes but should not include sensitive client personal information. Customers are responsible for ensuring that any Content they upload complies with their own privacy obligations.

3. How We Use Your Personal Information

We use personal information we collect for the following purposes:

• to create and manage your Account and provide access to the Platform;
• to process Subscription payments via Stripe;
• to communicate with you about your Account, including billing, service updates, and support;
• to send marketing and promotional communications via Klaviyo, where you have consented to receive them;
• to respond to enquiries submitted via our website contact form;
• to monitor and improve the performance and security of the Platform;
• to comply with our legal obligations; and
• to enforce our Terms and Conditions.

We will not use your personal information for any purpose that is not described in this Privacy Policy without first obtaining your consent, unless we are required or authorised to do so by law.

4. Disclosure of Personal Information to Third Parties

We may disclose your personal information to the following third parties for the purposes described in this Privacy Policy:

Stripe

We use Stripe to process subscription payments. When you provide payment details, those details are transmitted directly to and stored by Stripe. We do not store your full payment card details. Stripe's privacy policy is available at stripe.com/au/privacy.

Klaviyo

We use Klaviyo to manage email marketing communications. Your name and email address may be stored in Klaviyo where you have consented to receive marketing communications from us. Klaviyo's privacy policy is available at klaviyo.com/legal/privacy-notice.

Google Analytics

We use Google Analytics to analyse website traffic and usage. Google Analytics collects anonymised usage data via cookies. Google's privacy policy is available at policies.google.com/privacy. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

Anthropic and OpenAI

As set out in our AI Disclosure Statement, Anthropic (Claude API) and OpenAI (Embeddings API) process Customer Content as part of delivering the AI Staff Assistant.

Stackup Solutions (Hosting, Infrastructure and Development)

Stackup Solutions is our hosting, infrastructure, and development partner. Your data, including Customer Content, is stored on servers located in Paris, France. We use the hosting provider's native DNS services and do not use Cloudflare or any other third-party DNS provider.

We do not sell, rent, or trade personal information to any third party for their own marketing purposes.

We may disclose personal information to law enforcement, government agencies, or other third parties where required by law, court order, or where we reasonably believe disclosure is necessary to protect our rights, your safety, or the safety of others.

5. Cross-Border Disclosure

Some of our third-party service providers, including Stripe, Klaviyo, and Google Analytics, may store or process data on servers located outside Australia.

In addition, our core hosting infrastructure, provided by Stackup Solutions, is located in Paris, France. This means Customer Content and other personal information described in this policy is stored outside Australia as a matter of course, not only via third-party integrations.

Where personal information is disclosed to overseas recipients, we take steps intended to ensure those recipients handle your information in a manner consistent with the Australian Privacy Principles. By using our Platform and website, you consent to your personal information being disclosed to and stored by overseas recipients as described in this Privacy Policy.

6. Data Security

We take reasonable technical and organisational measures to protect personal information from unauthorised access, loss, misuse, disclosure, or alteration. These measures include:

• encrypted data transmission using SSL/TLS;
• access controls limiting who can access personal information within our organisation;
• isolated data environments ensuring each Customer's data is accessible only to that Customer and their authorised Staff Users; and
• regular review of our security practices.

Despite these measures, no method of data transmission or storage is completely secure. We cannot guarantee the absolute security of personal information. If you become aware of any security concerns, please contact us immediately at hello@glowuphub.com.au.

7. Data Retention and Deletion

We retain personal information for as long as necessary to provide our services and comply with our legal obligations. Specifically:

• Account information is retained for the duration of your Subscription and for 30 days following cancellation or termination;
• Content uploaded to the Platform is permanently deleted 30 days after cancellation or termination of your Account;
• billing and transaction records are retained for 7 years as required under Australian tax law; and
• website enquiry and contact form submissions are retained for up to 2 years.

You may request deletion of your personal information at any time by contacting us at hello@glowuphub.com.au. We will process deletion requests within 30 days, subject to any legal obligations that require us to retain certain information.

8. Cookies and Tracking

Our website uses cookies and similar tracking technologies to improve your browsing experience and analyse website usage. Cookies are small text files stored on your device when you visit our website.

We use the following types of cookies:

• Essential cookies: necessary for the website and Platform to function correctly. These cannot be disabled.
• Analytics cookies: used by Google Analytics to collect anonymised information about how visitors use our website. This helps us improve our content and services.
• Marketing cookies: used to track visitors across websites and display relevant advertising. These are only active where you have provided consent.

You can control cookies through your browser settings. Disabling cookies may affect the functionality of our website. For more information about managing cookies, visit allaboutcookies.org.

9. Your Privacy Rights

Under the Australian Privacy Act 1988 (Cth), you have the right to:

• access the personal information we hold about you;
• request correction of personal information that is inaccurate, incomplete, or out of date;
• request deletion of your personal information, subject to our legal retention obligations;
• opt out of direct marketing communications at any time by clicking "unsubscribe" in any marketing email or by contacting us at hello@glowuphub.com.au; and
• make a complaint about how we have handled your personal information.

To exercise any of these rights, please contact us at hello@glowuphub.com.au. We will respond to all requests within 30 days. In some circumstances we may need to verify your identity before processing a request.

10. Privacy Complaints

If you believe we have breached the Australian Privacy Principles or otherwise mishandled your personal information, please contact us in the first instance at hello@glowuphub.com.au. We will acknowledge your complaint within 5 business days and endeavour to resolve it 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):

• Website: oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001

11. Children's Privacy

Our Platform is not directed at children under the age of 18. We do not knowingly collect personal information from anyone under 18 years of age. If you believe we have inadvertently collected personal information from a child, please contact us at hello@glowuphub.com.au and we will take steps to delete that information promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices, the Platform, or applicable law. We will notify you of material changes by email at least 30 days before the updated policy takes effect. The current version of our Privacy Policy will always be available at glowuphub.com.au/privacy.

Your continued use of the Platform after the effective date of any update constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or our handling of your personal information, please contact us: