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 by Pao 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 and App (www.paower.com.au and the PAOWER mobile/web application), customers purchasing any of our products or services, and individuals who interact with us in any way.

PAOWER serves clients based in Australia and internationally, including clients from Colombia, the United States and other countries. Regardless of where you are located, your information is handled under Australian privacy law.

2. Our Products & Services

This Policy applies to all PAOWER offerings, including:

• PAOWERMethod — a group membership program structured in 4 phases, available as a monthly or 6-month subscription.

• PAOWERYou — personalised 1:1 coaching (training and nutrition), minimum 12-week commitment, weekly billing.

• PAOWERFocus — personalised coaching focused on either training or nutrition only, minimum 12-week commitment.

• PAOWERFull — a time-bound, fixed-scope program.

• PAOWER Challenges — time-bound group programs (typically 6 weeks), available as a one-time payment.

• Any other digital products, resources, lead magnets, newsletters, or community offerings provided by PAOWER.

3. What We Collect

3.1 Identity & Contact Information

Full name, date of birth or age range, email address, phone number (including country code), country and city of residence, time zone.

3.2 Account & Usage Data

Usernames, hashed passwords, in-app actions and activity, device identifiers, IP address, browser type, operating system, app version, crash logs, referral data, cookies and similar technologies.

3.3 Training, Nutrition & Optional Health Data

Self-reported goals, training history and experience level, food preferences, allergies and intolerances, height, weight and body measurements, progress photos and videos, adherence logs, wearable or app-synced metrics (where you choose to connect them).

Important — Health & Fitness Data:
As part of our onboarding process, we collect health and fitness information through intake questionnaires and, where applicable, a Pre-Exercise Health Declaration (PAR-Q). This information is collected to support your safety and allow our coaches to guide you appropriately.
PAOWER coaches are qualified Sports Nutritionists and Fitness Coaches — not medical doctors, physiotherapists, or registered dietitians. Health data you provide is used solely for coaching, program delivery, safety assessment and service improvement. It is never used for unrelated marketing without your explicit consent.
You are not required to provide health information beyond what is necessary for safe participation. However, withholding relevant health information may affect our ability to support you safely.

3.4 Transaction Data

Order details, program or membership tier, 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 authorised payment providers whose own privacy policies also apply.

3.5 Communications & Community

Support messages, email marketing preferences, survey and feedback responses, testimonials, reviews, community interactions and check-in submissions.

3.6 Derived & Analytics Data

Ratings and reviews you post publicly; analytics and usage profiles derived from your interactions with our Platforms; aggregated and de-identified data used for product improvement and reporting.

4. How We Collect Your Information

• Directly from you — through sign-ups, purchases, onboarding intake forms, Pre-Exercise Health Declarations, in-app entries, email, chat and community participation.

• Automatically — via cookies, SDKs, analytics tools, performance logs and security monitoring when you use our Website or App.

• From Service Providers — such as payment confirmation data, deliverability signals and anti-spam checks.

• From third-party integrations — only if you choose to connect external services (e.g., wearables, app stores).

5. Purposes of Use

We use your personal information to:

• Create and manage your Account and profile.

• Deliver, personalise and support your program — whether PAOWERMethod, a personalised coaching program, a Challenge, or any other PAOWER offering.

• Review and act on health and fitness information you provide through intake forms and health declarations, to support your safety and appropriate program delivery.

• Process payments, manage subscriptions, prevent fraud and manage billing entitlements.

• Operate, maintain and secure the App and Website, including diagnostics and crash reporting.

• Send service messages, program updates and changes to our Terms and Conditions.

• Send marketing communications, which you can opt out of at any time.

• Conduct analytics and product improvement to make our services better.

• Comply with applicable laws, respond to lawful requests and enforce our Terms.

6. Legal Bases (Where Applicable)

• Performance of a contract with you — to deliver the program or service you have purchased.

• Legitimate interests — service security, fraud prevention, analytics, product improvement and community safety.

• Consent — for optional health data, marketing emails, and use of progress photos or testimonials for marketing purposes.

• Legal obligations — tax, regulatory compliance and record-keeping requirements.

7. Health Data & Sports Nutrition Scope of Practice

PAOWER collects health-related information as part of its onboarding process for all programs. This includes information provided in intake questionnaires and Pre-Exercise Health Declarations (PAR-Q forms).

This information is treated with the highest level of care and confidentiality. We use it exclusively for the following purposes:

• To assess whether participation in a PAOWER program is appropriate and safe for you.

• To allow our coaches to adapt guidance, flag concerns and refer you to appropriate medical professionals where needed.

• To comply with our duty of care as fitness and sports nutrition professionals.

• To improve the quality and safety of our programs.

Scope of Practice — Important:
PAOWER coaches are qualified Sports Nutritionists and Fitness Coaches. They are not medical doctors, registered dietitians, physiotherapists, or mental health practitioners.
Nutrition guidance provided through PAOWER is based on sports nutrition principles and is educational in nature. It is not medical nutrition therapy and does not replace advice from a qualified medical professional or registered dietitian.
If you have a diagnosed medical condition that may be affected by exercise or dietary changes, we strongly encourage you to consult a medical professional before starting any PAOWER program.

If your health status changes at any point during your program — including new diagnoses, new medications, surgery, or pregnancy — you agree to notify your PAOWER coach promptly.

8. Disclosures to Third Parties

We may disclose your personal information to:

• Service Providers: hosting and infrastructure (including FitBudd), cloud storage and CDNs, payment processors (Stripe/PayPal), analytics, error monitoring, email and SMS messaging platforms, customer support tools, and identity and security services. These parties access your information only as reasonably necessary and must handle it under appropriate safeguards.

• Professional advisers: auditors, accountants, lawyers and insurers, where necessary for our business operations.

• Regulatory authorities: when required or compelled by law, court order, or a lawful government request.

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

We do not sell your personal information to any third party.

9. International Clients & Overseas Processing

PAOWER is an Australian business operating under Australian law. We welcome clients from Australia and internationally, including from Colombia, the United States and other countries.

Regardless of where you are located, by using our services you agree that:

• Your personal information is handled in accordance with Australian privacy law, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

• Australian law governs the collection, use and protection of your data.

• US HIPAA rules do not apply to our services.

Your information may be stored or processed outside Australia (for example, in cloud infrastructure operated by our Service Providers in the United States or other regions). We take reasonable steps to ensure that overseas recipients handle your information in a manner consistent with the APPs, including through contractual obligations and technical safeguards.

10. Marketing, Emails & Notifications

• We send service and transactional emails that are necessary for your program — these cannot generally be unsubscribed from while you are an active client.

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

• We may use de-identified and aggregated data to form advertising audiences. No directly identifying information is shared with advertisers.

• If you sign up for our newsletter, lead magnet or free resources, you consent to receiving emails from PAOWER. You may unsubscribe at any time.

11. Progress Photos, Testimonials & Social Media

With your explicit consent, we may use your progress photos, before-and-after images, testimonials, reviews and community messages for PAOWER marketing and promotional purposes across our website, social media channels, email campaigns and other platforms.

Your consent options are presented at the time of purchase or enrollment. You may:

• Consent to full use of your photos and testimonials including your face and name.

• Consent to anonymous use only (without showing your face or identifying details).

• Decline consent entirely.

You may withdraw your marketing consent at any time by emailing hola@paower.com.au. We will cease new uses within a reasonable time. Please note that content already published or shared — including on social media or in community groups — may persist in archives, reposts, or platforms beyond our direct control.

12. Data Security

We implement reasonable administrative, technical and physical safeguards proportional to the sensitivity of the information we hold. These include encryption in transit, access controls, activity logging, monitoring, least-privilege access principles and vulnerability management practices.

Health-related information collected through intake forms and health declarations is treated with additional care and is accessible only to your assigned PAOWER coach and necessary operational staff.

No system is 100% secure. While we take our obligations seriously, we cannot guarantee absolute security of information transmitted over the internet.

13. Retention

We retain your personal information for as long as necessary to deliver our services, fulfil the purposes described in this Policy, and meet our legal, accounting and record-keeping obligations.

Health and fitness data collected during your program (including intake forms, health declarations, progress photos and check-in records) is retained for the duration of your program and for a reasonable period thereafter for legal and safety purposes.

When information is no longer needed, we de-identify or securely delete it where reasonable and technically feasible.

14. Your Rights & Choices

Subject to the APPs and applicable legal exceptions, you have the right to:

• Request access to the personal information we hold about you.

• Request correction of inaccurate, outdated or incomplete information.

• Request erasure or de-identification of your information where appropriate.

• Opt out of marketing communications at any time.

• Withdraw consent for specific processing (e.g., optional health data use, progress photo marketing).

To exercise any of these rights, contact us at hola@paower.com.au. We may need to verify your identity before processing your request and will respond within a reasonable period in accordance with the APPs.

15. Cookies & Tracking

We use cookies, SDKs and similar technologies for session management, user preferences, analytics, security monitoring and performance optimisation. These may be set by PAOWER directly or by our Service Providers.

You can modify your browser settings to block or delete cookies; however, some features of our Website or App may not function correctly if you do so.

16. Children & Minors

Our services are designed for adults aged 18 and over. Users aged 16–17 may access our services only with the explicit consent and active supervision of a parent or guardian, who must accept our Terms & Conditions on their behalf.

We do not knowingly collect personal information from individuals under the age of 16. If we become aware that we have inadvertently collected information from a child under 16, we will take steps to delete it promptly. If you believe this has occurred, please contact us at hola@paower.com.au.

17. Notifiable Data Breaches

We take data breaches seriously. If an eligible data breach occurs under the Notifiable Data Breaches (NDB) scheme, we will:

• Assess the breach promptly to determine whether it is likely to result in serious harm to any affected individuals.

• Notify affected individuals and the Office of the Australian Information Commissioner (OAIC) where required under the NDB scheme.

• Provide recommended steps affected individuals can take to mitigate potential harm.

18. Complaints

If you have a concern or complaint about how PAOWER has handled your personal information, please contact us first:

Email: hola@paower.com.au

We will investigate your complaint and respond within a reasonable timeframe. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC):

• Website: oaic.gov.au

• Phone: 1300 363 992

19. HIPAA

The US Health Insurance Portability and Accountability Act (HIPAA) does not apply to PAOWER’s services. PAOWER is an Australian entity operating under Australian law. International clients, including those based in the United States, agree that their data is handled in accordance with Australian privacy law.

20. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes to our services, legal obligations or business practices. Material changes will be posted on our Website and App with an updated “Last updated” date.

Continued use of our services after an update is posted constitutes your acceptance of the revised Policy. If changes are significant, we may also notify you directly by email.

CONTACT US

PAOWER by Pao | hola@paower.com.au | www.paower.com.au

ABN 62 139 866 281 | Queensland, Australia

Privacy complaints: hola@paower.com.au | OAIC: oaic.gov.au | 1300 363 992