PAOWER by Pao — Privacy Policy (Australia)

Last updated: 1 October 2025
Entity: PAOWER by Pao (ABN 62 139 866 281)
Contact (privacy): hola@paower.com.au
Website/App: www.paower.com.auand the PAOWER mobile/web application
Technical Provider: FitBudd Inc. (platform development/hosting) and other Service Providers.

1. About this Policy

This Privacy Policy explains how PAOWER collects, uses, discloses and protects personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). It applies to all users of our Website/App, customers purchasing our products/services, and individuals who interact with us.

2. What We Collect

We may collect the following categories of information:

2.1 Identity & Contact
Name, date of birth/age range, email, phone, country/state, time zone.

2.2 Account & Usage
Usernames, passwords (hashed by our systems/service providers), in-app actions, device identifiers, IP address, browser type, OS, app version, crash logs, referral data, cookies and similar technologies.

2.3 Training/Nutrition & Optional Health Data
Self-reported goals, training history, food preferences, allergies, height/weight, measurements, progress photos, adherence logs, wearable or app-synced metrics (where you connect them). You are not required to provide health information; providing it is optional and used to personalise coaching if you choose to share it.

2.4 Transactions
Order details, plan tiers, subscription status, billing history, limited card metadata and payment tokens. We do not store full card numbers; payments are processed by Stripe/PayPal or other payment providers.

2.5 Communications & Community
Support messages, email marketing preferences, survey responses, testimonials and reviews.

2.6 Public/Derived Data
Ratings/reviews you post publicly; analytics and profiles derived from your interactions with our services.

3. How We Collect

· Directly from you (sign-ups, purchases, forms, in-app entries, email, chat).

· Automatically via the App/Website (cookies/SDKs, analytics, performance and security logs).

· From Service Providers (e.g., payment confirmations, deliverability/anti-spam signals).

· From third-party integrations only if you connect them (e.g., wearables or app stores).

4. Purposes of Use

We use personal information to:

· create/manage your Account; deliver, personalise and support Programs (personalised and non-personalised);

· process payments, prevent fraud, manage subscriptions and entitlements;

· operate, maintain and secure the App/Website (including diagnostics and crash reports);

· communicate service messages, updates and changes to Terms;

· send marketing communications you can opt out of at any time;

· conduct analytics, product improvement and quality assurance;

· comply with laws, respond to lawful requests, and enforce our Terms.

5. Legal Bases (where applicable)

· Performance of a contract with you;

· Legitimate interests (e.g., service security, analytics, improvement);

· Consent (e.g., optional health data, marketing emails, progress photo marketing);

· Legal obligations (e.g., tax, regulatory).

6. Disclosures to Third Parties

We may disclose personal information to:

· Service Providers: hosting (incl. FitBudd), cloud storage/CDNs, payments (Stripe/PayPal), analytics, error monitoring, messaging/email/SMS, customer support tools, identity/security services. These parties may access information only as reasonably necessary and must handle it under appropriate safeguards.

· Professional advisers: auditors, accountants, lawyers and insurers.

· Authorities: when compelled by law, court order or lawful request.

· Business transfers: in connection with a merger, acquisition or asset sale, subject to appropriate protections and continuity of privacy commitments.

We do notsell personal information.

7. Overseas Processing & Transfers

Your information may be stored/processed outside Australia (e.g., cloud regions or Service Provider locations). We take reasonable steps to ensure overseas recipients handle your information in a way that is consistent with the APPs (contractual obligations, technical/organisational safeguards).

8. Marketing, Emails & Notifications

· We may send you service and transactional emails (cannot generally be unsubscribed).

· With your consent (or as otherwise permitted by law), we send promotional and informational emails. You can unsubscribe at any time via the link in the email or by contacting hola@paower.com.au.

· We may use de-identified data for advertising audience formation (no direct identification shared with advertisers).

9. Optional Health Data & Sensitive Information

If you choose to provide health-related information for personalisation, we will use it onlyfor coaching and program delivery, safety, support, and quality improvement. You can delete or update this information via your Account or by contacting us. We do not use health data for unrelated marketing without your explicit consent.

10. Progress Photos, Testimonials & Social Media

With your consent, we may use your progress photos/testimonials for marketing. You may withdraw consent at any time by emailing hola@paower.com.au; we will cease new uses within a reasonable time and remove where feasible (past publications may persist in archives/replications beyond our control).

11. Data Security

We implement reasonable administrative, technical and physical safeguards proportional to risk (encryption in transit, access controls, logging/monitoring, least-privilege access, vulnerability management). No system is 100% secure.

12. Retention

We retain personal information for as long as necessary for the purposes described in this Policy and to meet legal/accounting/record-keeping obligations. We then de-identify or securely delete it where reasonable.

13. Your Rights & Choices

Subject to the APPs and limited exceptions, you may:

· request accessto your personal information;

· request correctionof inaccurate, outdated or incomplete information;

· request erasure/de-identificationwhere appropriate;

· opt out of marketingat any time;

· withdraw consent for specific processing (e.g., health data, photo marketing).

Contact hola@paower.com.auto exercise your rights. We may need to verify your identity and we will respond within a reasonable period.

14. Cookies & Tracking

We use cookies/SDKs for session management, preferences, analytics, security and performance. You can modify browser settings to block cookies, but some features may not function properly.

15. Children

Our services are designed for adults. Users aged 16–17 require parent/guardian consent and supervision. We do not knowingly collect personal information from children under 16.

16. Notifiable Data Breaches

If an eligible data breach occurs under the Notifiable Data Breaches scheme, we will assess promptly and notify affected individuals and the OAIC where required, including recommended steps to mitigate harm.

17. Complaints

If you have a privacy complaint, contact hola@paower.com.au. We will investigate and respond. If you are not satisfied, you may contact the Office of the Australian Information Commissioner (OAIC)at oaic.gov.au or 1300 363 992.

18. HIPAA

The US Health Insurance Portability and Accountability Act (HIPAA) does not apply to our services.

19. Changes to this Policy

We may update this Policy from time to time. Material changes will be posted on the Platforms with the “Last updated” date. Continued use after an update constitutes acceptance.