Grace Papers Cares About Your Privacy

Transparency and honesty are a huge part of our mission at Grace Papers Pty Ltd. We care about your privacy and especially about the psychological safety of the coaching environment. Whether you are a coach providing services on our platform, a user of our platform, an entity that contracts on behalf of users, or a visitor to our website, we want you to know how we collect, use and share your data.

We also want to communicate this Privacy Policy in plain language, as much as possible.

Introduction and Definitions

This Privacy Policy describes our privacy practices relevant to the Site, our coaching and consulting services (collectively the “Services”) and the Grace Papers platform (“Platform”) and the impact these practices have on Site Visitors, Coaches, Users, User Organisations and any other person who comes into contact with us. Each term is defined below. Let us start with a brief overview of what we do, how and where we might be collecting data and then define some relevant terms.

Grace Papers is the first career coaching platform to transform gender equality and development for people, teams, and organisations where it matters most – career and leadership development. At the same time, companies need a systemic, business-led approach to gender equality (social and work systems, intersectional lens) as well as a framework for tracking progress (individual, groups, leaders and governance) – a total solution provided by our Platform.

Our vision is for a world in which women and men are equally responsible for the most important decisions made; where all people, regardless of gender, can be vulnerable and combine career, care and ambition without stigma; a world where work is compatible with the modern lives of families.

We distinguish between the people to whom we provide Services directly via the Platform (referred to as “Users”) and the entities who contract with us to provide Services to their employees or others on the Platform (referred to as “User Organisations”). We collect, use and share data differently for Users and User Organisations, although they might sometimes be one and the same. If you receive Grace Papers Services via your employer or another sponsoring organisation, please be aware of the data which may be shared back to your User Organisation as a result of using the Platform (refer to section 5).

We also collect data from business coaches (“Coaches”) who contract with us to provide services to Users via the Platform and from visitors (“Visitors”) to our website www.gracepapers.com.au (the “Site”).

To the extent data is associated with an identified or identifiable natural person and is protected under applicable data protection laws including the Privacy Act 1988 (Cth) and Privacy Act 2020 (NZ), we refer to such data as “Personal Data”.

What types of Personal Data is collected and the purposes for collection

Data from our Site

If you are a visitor to our public Site we will collect certain information. We use cookies to collect data to recognise you and your device(s) across services and devices where you have engaged with our Site. We also allow third parties to use cookies as described in this policy.

A “cookie” is a small file stored by your browser when you access a website.

We use cookies and tracking technologies for authentication and to tailor the Site to user preferences. Session cookies expire when the browsing session ends.

You may refuse cookies via your browser settings, but this may limit Site functionality.

We treat Personal Data collected by cookies in the same way as other Personal Data under this Policy.

Grace Papers and analytics

We use analytics, including machine learning (ML), to customise and enhance Services such as our Time-Based Rules Engine (TBRE) and Session Insights algorithm. These rely on User actions and inputs.

When you browse the Site, our hosting providers and third parties may collect information for statistical and maintenance purposes. This may include:

• number of users and pages viewed
• date, time and duration of visits
• browsing patterns
• IP address
• navigation paths

This information is used to improve performance and is not used to identify you.

We use analytics tools to understand how the Site and Platform are used, including responses to surveys and assessments. These tools generate statistical reports and may store data. We do not use analytics to collect personally identifiable information or combine it with other identifiable data.

Data from Coaches

We collect data when Coaches apply, use the Platform, request support, or communicate with us. This includes name, phone number, work address, and experience.

We do not require sensitive financial data. We may optionally request demographic data (e.g. gender, ethnicity) for research or program needs.

We may review coaching sessions for training or research, minimising personal data where possible.

Coaches may provide feedback or update preferences (e.g. pronouns, language).

Providing Personal Data is voluntary, but we require basic details (name, email, phone, bank details) to engage Coaches.

Data from Users

We collect data when Users register and use the Platform, including:

• name
• email
• gender
• parental leave dates
• phone number
• role or title

We may also collect demographic data such as:

• postcode
• commute time
• nationality
• years in Australia
• industry

This data is used to create accounts, personalise experiences, and deliver relevant services.

We may request additional information such as survey responses, feedback, and profile preferences.

Users and Coaches can access survey responses to support coaching. User Organisations receive only aggregated, de-identified data.

We also collect usage data such as session attendance, program engagement, and ratings.

Providing data is voluntary, but failure to do so may limit access to Services.

Data we collect about Users from others

User Organisations may provide demographic or employment data when enrolling Users or integrating HR systems. This may include contact details and manager information.

Third-party integrations may also provide data to support insights and reporting.

Aggregated data

We collect aggregated and de-identified data from Platform usage to improve Services.

We use limited tracking technologies and do not collect precise geolocation data.

Customer support

We collect data provided during support interactions to verify identity and resolve issues.

Data about other parties

We collect Personal Data from suppliers, contractors, and job applicants, including contact and employment details.

Employee records are handled separately under applicable law.

How we use your Personal Data

We do not sell Personal Data unlawfully.

We use Personal Data to:

• provide and improve Services
• respond to queries
• maintain the Site and Platform
• personalise user experience
• send communications and updates
• conduct surveys and generate reports
• process applications
• comply with legal obligations

Our primary use of data is to deliver and improve Services and generate insights, mostly using de-identified data.

How we share your Personal Data

We share data between Users and Coaches to enable communication and coaching.

If you access Services via a User Organisation, we may share:

• registration and usage data
• session attendance and completion metrics

We do not share coaching session details without consent.

User Organisations may receive aggregated, de-identified insights.

We may share data with:

• service providers
• legal authorities where required
• parties involved in business transfers

We may also share data with your consent or where permitted by law.

Overseas disclosure of Personal Data

We may disclose data to recipients outside Australia or New Zealand, including the United States.

We take reasonable steps to ensure overseas recipients handle data consistently with Australian Privacy Principles.

Your Choices, Rights and Obligations

We retain data only as long as necessary.

At the end of your Platform licence, we will ask if you wish to continue. If not, we will delete your Personal Data except where retention is legally required.

You may:

• access or correct your data
• make complaints
• contact us regarding privacy concerns

We will respond within a reasonable time.

If unresolved, you may contact relevant regulators such as the OAIC or NZ Privacy Commissioner.

You can opt out of marketing communications at any time.

Other important information

If we update this Privacy Policy, we will notify you via the Site or email where appropriate. We encourage regular review of the Policy.