PRIVACY POLICY

Effective date: 20/08/2025

  1. ABOUT THIS POLICY

Last updated: 20/08/2025

  • This Privacy Policy (Policy) applies to The Relationship Hub (TRH), operated by Angela O'Connor (ABN 69 840 731 125) ("we", "our", or "us"). This Privacy Policy (Policy) lets you know what personal information we collect, what we do with it, when we may disclose it, and how you can access or correct the personal information we hold about you.
  • We provide online programs, courses and counselling.
  • This Policy describes how we meet our obligations under the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). Please read our Policy below carefully.
  • This Policy does not apply to the personal information of our current or former employees.
  1. KEY DEFINITIONS
    • In this Policy:
      • personal information means any information or opinion, whether true or not, and whether recorded in material form or not, about an identified individual or an individual who is reasonably identifiable. Personal information does not include information that is properly de-identified. Personal information also includes health information and sensitive information;
      • sensitive information is a subset of personal information. Sensitive information includes information or an opinion about an individual's race, gender diversity, sexual orientation or practices, disability, ethnic origin, political opinions, religious or philosophical beliefs and affiliations, and criminal record, in circumstances where that information Is also personal information. Sensitive information also includes health information about an individual, genetic information and biometric information or templates. Sensitive information is generally awarded a higher level of privacy protection than other types of personal information;
      • health information means any information or opinion about the health, disability or injury of an individual. It also includes information or opinion about a health service provided, or to be provided to an individual, including the individual's expressed wishes of future provision of health services. Health information also includes any genetic information about an individual that is, or could be predictive of the health of the individual, or their genetic relative.
  1. TYPES OF PERSONAL INFORMATION WE COLLECT
    • In the course of your interactions with us, we may obtain the following personal information from or about you:
      • your full name;
      • contact details such as your address, phone number, and email address;
      • details current court orders;
      • names and details of family members;
      • details of experiences regarding grief and loss;
      • previous counselling received;
      • your financial information (e.g. credit card details)
      • health information and medical history; and
      • other personal information you disclose to us from time to time.
    • The type of personal information we collect about you depends on the dealings you have with us.
  2. PURPOSES FOR WHICH WE COLLECT YOUR PERSONAL INFORMATION
    • We collect your personal information for the following purposes:
      • to manage and conduct our business;
      • to comply with our legal obligations, resolve any disputes;
      • enforce our agreements and rights with third parties;
      • to communicate with you;
  1. WHAT HAPPENS IF YOU DO NOT PROVIDE US YOUR PERSONAL INFORMATION
    • If you choose not to provide us with some or any of your personal information, we may not be able to provide our services to you, or process your payments.
  2. DEALING WITH US ANONYMOUSLY OR USING A PSEUDONYM
    • Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question, we will not record your name unless we need it to adequately respond to your question.
    • However, for many of our functions and activities, we usually need your name, contact information and other details as notified from time to time.
  1. COLLECTION OF PERSONAL INFORMATION VIA OUR WEBSITE

7.1 When you visit our website, we may use cookies or other similar tracking technologies. A cookie is a small file placed in your web browser that collects information about your browsing behaviour. Cookies help tailor website configuration to your needs and preferences. They do not access information stored on your computer or any personal details (e.g., name, address, email address or phone number). You can reject cookies by adjusting your browser settings; however, this may limit full functionality of our website.

7.2 We may also use tracking technologies such as JavaScript or analytics tools (e.g., Google Analytics) to gather information about pages viewed, how you navigated to them, and the duration of your visit. While you can disable these tools via your browser, doing so may affect website formatting and usability.

7.3 While this browsing data does not identify you personally, we may record certain information such as pages visited, time and date of your visit, referral source (e.g., search engines), and your IP address.

7.4 Some pages may contain electronic images known as web beacons. These are used to analyse overall website usage and are not used to collect personal information.

  1. COLLECTION AND HANDLING OF PERSONAL AND SENSITIVE INFORMATION FOR COUNSELLING SERVICES

8.1 If you book a counselling session or engage with our mental health services, we may collect personal and sensitive information from you. This may include your name, contact details, date of birth, relevant health or psychological history, and any other information you provide that is necessary to deliver counselling services safely and effectively.

8.2 We use Halaxy, a secure third-party practice management and booking platform, to manage appointment scheduling and basic contact details. Halaxy’s privacy and data security practices are governed by their own privacy policy, which you can view at Halaxy if you'd like.

8.3 Clinical notes from counselling sessions are not stored on Halaxy. Instead, they are maintained separately and securely on a password-protected personal computer, stored as Word documents. These files are accessible only by the practitioner and are not shared with any third parties unless legally required or expressly authorised by you.

8.4 All sensitive personal information is collected, stored, and handled in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and any relevant state health privacy laws.

8.5 We do not disclose your personal or health information to any third parties unless:

  • You provide explicit written consent;
  • Disclosure is required or authorised by law (e.g., to prevent serious harm);
  • We are legally compelled to do so by a court or statutory authority.

8.6 You have the right to access and request correction of any personal information we hold about you, subject to certain legal exceptions. Requests can be made by contacting us at The Relationship Hub.

8.7 Clinical records are retained for the legally required period (typically 7 years, or 7 years after a minor turns 18), after which they will be securely destroyed or de-identified.

  1. PERSONAL INFORMATION ABOUT CHILDREN

9.1 While our services are primarily directed toward adults, we may from time to time collect personal information about children (under the age of 18) in the course of delivering counselling services, particularly in contexts such as family therapy or where a parent or guardian seeks support involving a minor.

9.2 We do not directly market to or solicit personal information from children. Any information collected about a child is provided by, or with the consent of, a parent or legal guardian and is used solely for the purpose of delivering appropriate therapeutic services.

9.3 Personal information about children is handled with the same level of care, confidentiality, and legal protection as adult client information, and is stored and managed in accordance with this Privacy Policy, the Privacy Act 1988 (Cth), and relevant state-based health privacy laws.

9.4 In accordance with professional and legal obligations, records involving minors are retained until the individual turns 25 (i.e., 7 years after they reach the age of 18), unless a longer retention period is required.

  1. ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION

10.1 We take reasonable steps to ensure the personal information we collect is accurate, up to date, and complete.

10.2 You have the right to request access to the personal information we hold about you and to request corrections if you believe the information is inaccurate, incomplete, or out of date.

10.3 To make a request, please contact us at The Relationship Hub. We will respond within a reasonable time, typically within 28 days.

10.4 If we are unable to provide access or make the correction you request, we will explain why in writing and let you know how you can lodge a complaint.

  1. DIRECT MARKETING
    • With your consent, we may also use your personal information to send you direct marketing communications (such as updates or content we think you may be interested in). You can opt out of our direct marketing communications at any time by unsubscribing or emailing our Privacy Officer on the details provided below. We will action your request soon as possible.
  2. STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
    • We store your personal information electronically and take reasonable steps to protect it. Some data may be stored or processed by trusted third-party services that we use to run our business. These include:
    • Halaxy – for client appointment management
    • Kajabi – for our website, online programs, and course content
    • Stripe – for secure payment processing

Each of these platforms has its own privacy and security policies to protect your information.

  1. PROTECTING YOUR INFORMATION
    • We take reasonable steps to keep your personal information safe and secure. This includes protecting it from misuse, interference, loss, and unauthorised access, changes, or disclosure. Information you provide is stored securely, on password-protected systems.
    • To deliver our services, we may store and process your personal information using trusted service providers based outside Australia, such as Kajabi (for our website and programs) and Stripe (for payments). These companies help us run our business and support our services. We only use providers that have appropriate privacy protections in place, and by using our services, you consent to your information being transferred and stored overseas.
    • We retain your personal information for as long as needed to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
  2. DATA BREACH INCIDENTS
    • In the event we discover there has been actual or suspected unauthorised access to, disclosure, or use of your personal information (a data breach), we may notify you. We will work with you to mitigate the consequences, including harms, resulting from any such data breach.
    • We are required under the Privacy Act to notify the Office of the Australian Information Commissioner about certain data breaches.
  3. HOW WE USE AND DISCLOSE YOUR PERSONAL INFORMATION

15.1  We do not sell your personal information.

  • We only use or share your information to:
  • Provide our services to you
  • Meet legal or regulatory obligations
  • Communicate with you about your care, programs, or purchases
  • Improve our services or website (e.g. analytics tools)
  • We may share your information with trusted service providers who help us run our business, such as:
  • Halaxy (for appointment management)
  • Kajabi (for program delivery and communications)
  • Stripe (for payment processing)
  • Government or regulatory bodies, if required by law

15.3      All service providers we use are required to protect your information and use it only for the intended purpose.

15.4     If our business is ever sold or restructured, your personal information may be transferred under confidentiality terms, only where necessary to continue providing services.

  1. LINKS TO OTHER WEBSITES
    • Our website may include links to third-party websites for your convenience. We are not responsible for the privacy practices or content of those sites. We recommend reviewing their privacy policies if you choose to visit them, as this policy only applies to information collected on our website.
  2. UPDATES TO THIS POLICY
    • We may update this privacy policy from time to time. Any changes will take effect as soon as we post the updated policy on our website. We encourage you to check this page occasionally to stay informed about how we protect your information.
  3. CONTACT US
    • If you have any questions or concerns at any time about our privacy policy or the use of your personal information, please contact us at TRH ([email protected]) and we will respond within a reasonable timeframe.