PRIVACY POLICY
The Gratitude Project
Last updated: October 2026
1. About this policy
This policy explains how The Trustee for The Gratitude Project Trust (ABN 98 494 238 548), trading as The Gratitude Project ("we", "us", "our"), collects, uses, stores and discloses personal information.
It applies to our website at the-gratitude-project.com, our programs and services, our social media accounts, and our communications with you.
We are committed to handling personal information responsibly and consistently with applicable Australian privacy law, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles to the extent they apply to us.
2. What we mean by personal information
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. It includes obvious things like your name and email address, and less obvious things like your IP address or what you said on a recorded call.
3. What we collect
Contact and identity information. Your name, email address, phone number, social media handle, business name, country or time zone, and postal address where you provide it.
Payment information. Your billing name and address, and a record of what you've purchased and when. Card and payment details are processed by our payment providers (Stripe, PayPal, Klarna and Kajabi). We don't store your full card details.
Information you share while working with us. What you tell us about your business, audience, offers, pricing, revenue, goals and challenges in applications, forms, questionnaires, messages and calls.
Recordings and transcripts. Where a call is recorded, the audio and video of that call, and any transcript or summary generated from it. See section 8.
Communications. The content of messages you send us by email, Instagram, Telegram, our website contact forms or any other channel.
Technical and usage information. Your IP address, device and browser type, approximate location, the pages you visit, how you arrived at our site, and how you interact with our emails, including whether you opened them and what you clicked.
Information from third parties. Occasionally we receive information from our payment providers, our platforms or a publicly available social media profile.
Sensitive information. We don't generally seek sensitive information, such as health information, racial or ethnic origin, religious or political beliefs, or sexual orientation. Coaching conversations can be personal, and you may choose to share this kind of information with us. Please don't give us sensitive information about yourself or anyone else that isn't needed for your coaching. If you do choose to share it, we'll use it only for your coaching and related purposes in this policy.
4. How we collect it
Directly from you. When you subscribe to our emails, download a resource, fill in an application, buy a program, book or attend a call, or message us.
Automatically. Through cookies and similar technologies on our website and platform, and through tracking in our email system. See section 12.
From third parties. Our payment providers, our platforms or public social media profiles, as described above.
If you give us personal information about someone else, please make sure they're okay with that first.
5. Why we collect it
We use personal information to:
deliver the programs, services and resources you've purchased or requested
communicate with you, answer your questions and provide support
process payments, issue receipts and keep proper business records
run our community spaces and group programs
send you marketing communications where permitted (see section 6)
personalise what we send you, so it's relevant to your situation
improve our programs, content and website
keep our systems and business secure
meet our legal, tax and regulatory obligations.
We use personal information for these purposes, for related purposes you would reasonably expect, or where the law permits or requires it.
6. Marketing
Marketing messages. We send marketing emails and messages, such as news, offers and information about our programs, only where you've agreed to receive them or as otherwise permitted by law. For example, you can opt in by subscribing to our list or ticking a box when you sign up. Making a purchase does not, on its own, sign you up to our marketing.
Unsubscribing. Every marketing email or message includes a simple way to unsubscribe. You can also email us at hello@the-gratitude-project.com. You don't need to give a reason. We'll action your request promptly, and within 5 working days.
Program and service messages. If you're a client or participant, we'll also send you messages you need to receive what you've signed up for, such as login details, call links, schedule changes, receipts and account notices. These aren't marketing, so you'll keep receiving them while you're in a program even if you unsubscribe from marketing.
We don't sell, rent or trade your personal information.
7. Who we share it with
We use third-party service providers to help run our business. We share personal information with them only as reasonably needed for the services they provide to us. Each provider handles information under its own terms and privacy policy. Our main providers are:
Payment Processor: Stripe, PayPal, Klarna, Kajabi
Website, course hosting, email and scheduling: Squarespace, Kajabi
Call recording, transcription and summaries: Fathom
Instagram messaging automation: ManyChat
AI tools for drafting, summaries and administration: OpenAI (ChatGPT), Anthropic (Claude)
Cloud storage: Google Workspace
We may also share personal information with:
our team and contractors, where they need it to do their work for us. They are bound by confidentiality obligations
our professional advisers, such as accountants and lawyers, where relevant
anyone we're legally required to disclose it to, including regulators, law enforcement or a court
a buyer or new operator, if we sell or restructure the business, so the business can continue.
8. Call recording
Some of our coaching calls, group calls and workshops are recorded using Fathom.
We'll tell you before recording starts. If you don't want to be recorded, let us know. We can stop the recording, or you can stay off camera and off mic.
Recordings, transcripts and AI-generated summaries are used to:
deliver your coaching, including notes, summaries, action items and follow-ups
let participants rewatch a group call they attended or missed.
Group program recordings may be shared with other participants in that program. Private session recordings are not shared with other participants.
We won't use recordings, transcripts or what you say on a call in case studies, testimonials, marketing or training material unless you separately agree.
We keep recordings and transcripts only for as long as reasonably needed for these purposes (see section 11). You can ask us to delete a recording of a private session.
9. AI tools
We use AI tools to help run our business. These include Fathom for call transcription and summaries, and ChatGPT (OpenAI) and Claude (Anthropic) to help draft communications, summarise information and with general administration. This can involve personal information, such as your name, your messages and what you share on calls.
A person on our team reviews AI-drafted messages before they're sent. Some Instagram replies, such as sending a resource you've requested, are automated through ManyChat. We don't use AI or automated tools to make decisions that significantly affect your rights or interests.
We try to limit the personal information we put into AI tools to what's needed. Where these tools give us settings to limit how information is used, including for training AI models, we aim to use them. Each provider handles information under its own terms.
If you have questions about how we use AI tools, contact us at hello@the-gratitude-project.com.
10. Overseas disclosure
Some of our service providers store or process personal information outside Australia, including in the United States and other countries where they or their related entities operate.
11. Security and retention
Security. We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include limiting access to people who need it and using password-protected systems and established service providers. No online system is completely secure, and we can't guarantee the security of information held by third-party providers.
Data breaches. If a data breach is likely to result in serious harm to you, we'll act promptly to contain it and will notify you and the Office of the Australian Information Commissioner where required by law.
Retention. We keep personal information only for as long as reasonably required for the purposes for which it was collected, our legitimate business requirements and our legal obligations. We then delete or de-identify it where appropriate. Financial and business records may be kept for the periods required by law.
12. Cookies
Our website and platform use cookies and similar technologies to make the site work, keep you logged in, remember your preferences and understand how the site is used. Our email system also tracks whether emails are opened and which links are clicked.
We don't currently run advertising pixels on our website. If that changes, we'll update this policy.
You can set your browser to refuse cookies or alert you when one is set. Some parts of the site, including logging in to your programs, may not work properly if you do.
13. Access and correction
You can ask to access the personal information we hold about you, or ask us to correct it if it's inaccurate, out of date, incomplete, irrelevant or misleading. Email hello@the-gratitude-project.com.
We may need to verify your identity first. We aim to respond within 30 days. There's no charge for making a request, though we may charge a reasonable fee to cover the cost of giving you access.
If we refuse a request, we'll tell you why in writing, unless it would be unreasonable to do so, and how you can complain.
If you'd like us to delete information we hold about you, you can ask. We'll delete it where we no longer need it and aren't required to keep it.
14. Complaints
If you think we've mishandled your personal information, please tell us first. Email hello@the-gratitude-project.com with the details and we'll investigate and aim to respond within 30 days.
If you're not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC):
website: oaic.gov.au
phone: 1300 363 992
post: GPO Box 5288, Sydney NSW 2001.
15. Changes to this policy
We may update this policy from time to time. The current version is always at the-gratitude-project.com/privacy-policy and shows the date it was last updated. If we make a significant change, we'll let you know by email or a notice on our website.
16. Contact us
The Trustee for The Gratitude Project Trust, trading as The Gratitude Project
ABN 98 494 238 548