Privacy Policy

1. Introduction

Perineal Massage Coach ("we", "us", "our") is committed to protecting your privacy and handling your personal information in accordance with:

• the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs); and
• the Health Records Act 2001 (Vic) and the Health Privacy Principles (HPPs), where applicable.

This Privacy Policy explains how we collect, use, hold, and protect your personal information, including health information, in connection with your use of the Perineal Massage Coach application (the "App").

2. Who we are

The App is developed and operated by Jennifer Pol, trading as Perineal Massage Coach, as a sole trader registered in Victoria, Australia.

3. What information we collect

3.1 Information stored on your device

The following health-related information is collected voluntarily during setup and use, and is stored exclusively on your device. It is never transmitted to any external server. This information constitutes health information as defined under the Privacy Act 1988 (Cth) and the Health Records Act 2001 (Vic), and is treated with the highest level of protection afforded under those Acts.

3.2 Information held by us

We collect and hold the following information separately from your on-device health data:

Your email address is not used for marketing communications and will not be shared with third parties except as described in Section 7. It is collected and held separately from your health and progress data, and is not associated with any individual usage record within the App.

3.3 Information we do NOT collect

The App does not collect:

• Date of birth (other than confirming you are 18 or older at the consent step)
• Account login credentials of any kind
• Payment card or billing details (payments are processed entirely by a third-party payment provider — see Section 7.1)
• Gestational age, due date, or obstetric history
• Medical records or diagnostic information
• Phone number or postal address
• Location or GPS data
• Device identifiers or advertising IDs
• IP address or network information
• Camera, microphone, or contacts data

3.4 Technical and usage data

The App does not currently transmit any usage data, analytics, or crash reports to external servers. No tracking pixels, advertising SDKs, or third-party analytics tools are embedded in the App. See Section 10 for our cookies and analytics policy.

4. How we collect your information

We collect information directly from you when you:

• Provide your email address at purchase or registration to enable access recovery
• Complete the onboarding setup screens within the App
• Record session completions during use
• Update your schedule or reminder preferences in Settings
• Contact us directly with an enquiry or complaint

We do not collect information from third parties, data brokers, social media platforms, or any source other than your direct input.

5. Why we collect your information

We collect personal information to:

• Provide and maintain the App's core functionality
• Personalise session content to your stated goals and experience level
• Track and display your session progress and history
• Generate your chosen reminder schedule via local device notifications
• Reissue your access link if you change devices, reinstall the App, or experience a technical issue
• Improve App functionality and user experience over time
• Comply with applicable legal obligations

We collect only information that is reasonably necessary for these purposes, consistent with APP 3 (collection of solicited personal information). We do not use your information for marketing, profiling, research, or any secondary purpose without your express consent.

6. How your information is stored and secured

6.1 On-device health and progress data

• Your health data is private to your device only — we cannot access it remotely.
• If you uninstall the App, clear your browser data, or reset your device, this data will be permanently deleted.
• Because there is no cloud backup for this data, we have no ability to recover it on your behalf.
• If you use the App on multiple devices, this data is not synchronised between them.

6.2 Email address

Your email address is held by us securely and used solely for the purpose of reissuing App access links. It is stored separately from your on-device health data and is not linked to any individual usage record within the App. We take reasonable steps to protect it from misuse, unauthorised access, or disclosure.

6.3 Security measures

Our approach to security includes:

• Storing all health and progress data on-device only, eliminating server-side attack surfaces for this category of data
• Using encrypted HTTPS for any App updates, content delivery, and communications
• Minimising the categories of personal information collected to what is strictly necessary
• Designing the App without third-party tracking, analytics, or advertising code

The security of your on-device data also depends on the security settings of your own device. We recommend protecting your device with a strong PIN, password, or biometric lock. While we take reasonable precautions, no method of electronic storage is completely secure, and we cannot guarantee absolute security.

7. Disclosure to third parties

We do not sell your personal information. Your on-device health and progress data is not transmitted to any third party under any circumstances. Your email address is not disclosed to third parties except as described below.

7.1 Payment processing

Payments for App access are processed by Stripe. We do not receive or store your payment card details. Stripe's own privacy policy governs the collection and use of your payment data. No health information collected within the App is shared with Stripe. We may update the payment processor used in future versions of the App, and this policy will be updated accordingly.

7.2 Professional advisers

We may disclose information to professional advisers (such as legal or accounting advisers) where necessary, on a confidential basis. Any such disclosure would be limited to information reasonably required for the relevant advisory purpose and would not include your health or progress data.

7.3 Required disclosures

We may be required to disclose information where required by Australian law — for example, in response to a court order or a lawful request by a government or regulatory authority. Because all health and progress data is stored on-device only, we would not hold that information to disclose in these circumstances.

8. Cross-border disclosure

Australian Privacy Principle 8 governs the cross-border disclosure of personal information. Your on-device health and progress data is never transmitted to any server and is therefore not subject to cross-border disclosure.

Your email address and payment data may be processed by third-party service providers (including Stripe) whose infrastructure may be located outside Australia. Where this occurs, we take reasonable steps to ensure that appropriate privacy safeguards are in place, consistent with APP 8.1.

If the App's data storage architecture changes in a future version, this policy will be updated and you will be asked to review and re-consent before continuing to use the App.

9. Data retention

We retain personal information only for as long as necessary to provide the App's functions, maintain reasonable business records, and comply with applicable legal obligations.

9.1 On-device health and progress data

This data persists on your device until you actively delete it, clear app data, or uninstall the App. You may delete all on-device data at any time via Profile › Settings › Delete all my data. Deletion is immediate and permanent — we hold no server-side copy.

9.2 Email address

We retain your email address for as long as you hold an active access licence for the App. You may request deletion of your email address at any time by contacting us at info@perinealmassagecoach.au. We will action deletion requests within 30 days. Note that deletion of your email address may affect our ability to reissue your access link if a technical issue arises.

10. Cookies and analytics

The App does not currently use cookies, tracking pixels, advertising identifiers, or third-party analytics tools. No usage data is transmitted to external services.

If a future version of the App introduces analytics or performance monitoring tools, this policy will be updated accordingly and you will be notified and asked to consent before any such collection begins. You will at that time retain the ability to opt out of non-essential data collection.

If you access the App via a web browser, your browser may store session data locally in accordance with its own settings. You may manage or disable this through your browser's privacy settings, although this may affect App functionality.

11. Your rights — access, correction and deletion

11.1 Access and correction

Under APP 12 and HPP 6, you have the right to request access to personal information we hold about you, and to request correction of information that is inaccurate, out of date, incomplete, or misleading.

Your on-device health and progress data is directly accessible and editable within the App's profile and settings screens at any time. To access or correct your email address held by us, please contact us at info@perinealmassagecoach.au. We will respond within a reasonable timeframe and no later than 30 days.

11.2 Deletion

You may permanently delete your on-device data at any time by:

• Using the "Delete all my data" option in Profile › Settings, or
• Clearing your browser's local storage or app data through your device settings, or
• Uninstalling the App.

To request deletion of your email address held by us, contact info@perinealmassagecoach.au. We will action this within 30 days.

11.3 Grounds for refusal

We may refuse access or correction requests only where permitted under APP 12 or HPP 6 (for example, where providing access would unreasonably impact the privacy of another person, or is otherwise prohibited by law). We will notify you in writing if we decline a request and will provide our reasons, unless doing so would itself be unlawful.

12. Children

This App is intended for use by adults aged 18 years and over. We do not knowingly collect information from persons under 18. Users are required to confirm they are 18 or older as part of the consent process at first launch.

If you believe a person under 18 has used this App and provided personal information, please contact us at info@perinealmassagecoach.au and we will take reasonable steps to address this.

13. Changes to this policy

We may update this Privacy Policy from time to time. The updated version will be published within the App and will take effect upon publication.

If we make material changes — in particular, any change to data storage architecture, categories of information collected, third-party disclosures, or cross-border transfer arrangements — we will notify you within the App and ask you to review and re-consent before continuing to use the App.

The current version number and last updated date are displayed at the top of this document.

14. Complaints

14.1 Internal complaints

If you have a concern about how we have handled your personal information or health information, please contact us in the first instance:

14.2 Office of the Australian Information Commissioner (OAIC)

If you are not satisfied with our response, or if you believe we have interfered with your privacy, you may lodge a complaint with the OAIC:

14.3 Health Complaints Commissioner (Victoria)

For complaints relating to health information under the Health Records Act 2001 (Vic), you may also contact the Health Complaints Commissioner:

15. Contact us

For any privacy-related enquiries, access or correction requests, deletion requests, or complaints, please contact: