Privacy Policy
Effective Date: 8 October 2026
Entity: Fresh Learning (“The Fresh Coach”, “we”, “us”, “our”). Website: https://freshlearning.eu
At Fresh Learning, we are committed to protecting the privacy, confidentiality, and security of personal information collected from our clients, prospective participants, website visitors, and corporate sponsors.
This Privacy Policy outlines how we collect, use, disclose, and safeguard your information in accordance with the Australian Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the EU General Data Protection Regulation (GDPR) (EU 2016/679).
1. Information We Collect
We collect information necessary to deliver our executive coaching, cohort masterminds, diagnostic assessments, and digital resources.
Identity & Contact Data: Full name, job title, organizational role, business email address, phone number, and LinkedIn profile URL.
Diagnostic & Application Data: Responses to executive readiness surveys, organizational challenges submitted during application processes, and professional background details.
Transaction & Billing Data: Invoicing details, payment history, and corporate sponsorship information. (Note: Payment card processing is handled securely by third-party processors such as Stripe; we do not store full credit card numbers).
Technical & Usage Data: IP address, browser type, device information, pages visited, and interaction data collected via analytics tools and cookies when accessing our website or client portal.
2. Legal Basis for Processing (GDPR Compliance)
If you are located in the European Union (EU) or European Economic Area (EEA), we process your personal data under the following legal bases:
Contract Performance: Processing necessary to evaluate applications, enroll participants, and deliver The Executive Leadership Catalyst or digital resources.
Legitimate Interests: Processing necessary to improve our services, publish research, manage business operations, and maintain network security.
Consent: Where you have explicitly opted in to receive marketing communications, research whitepapers, or newsletter updates.
Legal Obligation: Compliance with Australian statutory accounting, tax, or legal requirements.
3. How We Use Your Information
We use collected information strictly for professional purposes, including:
Evaluating applications and diagnostic submissions for cohort suitability.
Facilitating live mastermind sessions, hot seat clinics, and peer-to-peer communication channels.
Granting access to digital downloads, executive toolkits, and client portals.
Processing payments and issuing corporate tax invoices.
Sending research updates, whitepapers, and program briefings (where opted in).
Meeting legal, administrative, and statutory reporting obligations.
4. Data Sharing & Third-Party Processors
We do not sell, rent, or trade personal information. We may share data with trusted third-party service providers solely to operate our business and deliver services, including:
Infrastructure & Analytics: Website hosting platforms (e.g., Framer), content management systems, and web analytics tools.
Payment Gateways: Secure payment processing engines (e.g., Stripe, Lemon Squeezy).
Communication & Delivery Platforms: Secure client portal software, email distribution platforms, and facilitated community channels (e.g., Slack/WhatsApp).
All third-party service providers are contractually required to maintain data confidentiality and comply with applicable privacy laws.
5. International Data Transfers
As an enterprise operating globally, information collected in Australia or the EU may be transferred to, stored, or processed on secure servers located outside your home country. Where EU personal data is transferred outside the EEA, we ensure appropriate safeguards are in place, such as standard contractual clauses (SCCs) or adequacy decisions.
6. Data Retention & Security
We implement enterprise-grade technical and organizational security measures to protect your data against unauthorized access, loss, misuse, or alteration.
We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy, satisfy legal or tax requirements, or resolve operational disputes. When data is no longer required, it is securely destroyed or anonymized.
7. Your Privacy Rights
Depending on your jurisdiction (Australia or EU/UK), you hold specific rights regarding your personal information:
Australian Privacy Principles (APPs):
Access: Request access to the personal information we hold about you.
Correction: Request corrections to inaccurate, incomplete, or out-of-date information.
EU General Data Protection Regulation (GDPR):
Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data where legal grounds apply.
Right to Restriction or Objection: Object to or restrict processing based on legitimate interests or direct marketing.
Data Portability: Request a structured, machine-readable copy of your data.
Withdraw Consent: Withdraw consent at any time where processing relies on consent.
To exercise any of these rights, please contact our Privacy Officer at richard.newton@freshlearning.eu.
8. Cookies & Analytics
Our website uses essential cookies to ensure standard functionality and analytical cookies to understand visitor engagement. You can manage or disable cookie preferences directly within your web browser settings.
9. Complaints & Contact Information
If you have questions, concerns, or wish to lodge a complaint regarding our privacy practices, please contact us directly:
Privacy Officer — Fresh Learning
Email: richard.newton@freshlearning.eu
Website: https://freshlearning.eu
If you are located in Australia and feel your complaint has not been adequately resolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au. EU residents may lodge a complaint with their local supervisory authority.
The Fresh Coach
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© The Fresh Coach 2026