Overview

This Privacy Policy explains how The Coherence Lab Pty Ltd (ACN [TO BE INSERTED]) (ABN [TO BE INSERTED]) ("The Coherence Lab", "we", "us", "our") collects, uses, stores, and protects personal information in connection with our services, including individual client engagements and corporate engagements delivered through partner organisations.

This Policy is aligned with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).

By engaging with our website, services, or programs, you agree to the collection and use of information in accordance with this Policy.

Information We Collect

We collect the following categories of personal information, depending on the nature of your engagement with us:

Identification and contact information: first and last name, email address, phone number, and mailing or business address where required.

Payment information: processed securely through third-party payment providers (Stripe and our banking partner). We do not store full payment card details.

Program and engagement data: where you engage with our programs (including the Sovereign Self System, The Before, the Coherence Map, and Cohort Integration Support), we collect:

  1. Responses you provide to the Coherence Profile and other intake or assessment instruments
  2. Information shared during sessions or in written communications between sessions
  3. Engagement data such as session attendance, threshold progression, and program completion markers
  4. Biometric and self-reported wellbeing data that you choose to integrate via the dashboard (such as Apple Watch / Health Auto Export data, Oura ring data via personal access token, manual saliva cortisol readings, and self-reported check-in responses)

Website usage data: standard website analytics (Google Analytics) collect anonymised usage data including pages visited, time on site, and referral sources. This data is not linked to identifiable individuals.

How We Use Your Information

Personal information is used solely for the following purposes:

  1. To communicate with you about your enquiry, application, booking, or engagement
  2. To deliver our programs and services
  3. To provide visibility to corporate engagement partners through the dashboard layer (limited to engagement and progression markers — see below)
  4. To process payments and manage invoicing
  5. To send you newsletters or updates, where you have subscribed
  6. To improve and develop our services
  7. To comply with legal and regulatory obligations
  8. To generate anonymised aggregate insights for service development, research, and marketing — no individual will be identifiable in any such use

We will not use your data for any purpose beyond what is described here without notifying you and obtaining your consent where required.

Confidentiality of Session Content

All information shared during 1:1 sessions, intake conversations, or written communication with practitioners is treated as strictly confidential. Session content is not disclosed to third parties — including corporate engagement partners such as Hoffmann Reed Transformation Advisory — without your explicit written consent. Where a corporate engagement partner has visibility of engagement data, that access is strictly limited to the dashboard permission framework described below.

Any testimonials, case studies, or anonymised insights shared publicly are done only with your explicit prior written consent, or in fully anonymised form where no individual is identifiable.

Corporate Engagements & Dashboard Permissions

Where you engage with The Coherence Lab through a corporate engagement (such as a partnership with Hoffmann Reed or another organisation), a three-tier dashboard permission structure applies:

  1. Kemina / Practitioner layer: your assigned practitioner has full access to your engagement, including the Coherence Profile, Coherence Map, session notes, and any biometric or check-in data you choose to share.
  2. Organisation layer: your engagement partner organisation has limited access — which threshold you're in, sessions completed, dates, and overall engagement markers. They do not have access to session content, Coherence Profile responses, Coherence Map content, biometric data, or qualitative practitioner notes.
  3. Individual leader layer: you have full visibility of your own engagement, including your Coherence Profile, Coherence Map, threshold progression, and any biometric or check-in data you've entered.

This permission structure is communicated to you at the start of any corporate engagement and forms part of the trust contract that makes the work effective.

Who We Share Your Information With

We do not sell your personal data. We share personal information only in the following circumstances:

  1. With corporate engagement partners (such as Hoffmann Reed), limited strictly to the organisation-layer visibility described above
  2. With trusted service providers who support our operations (hosting, payment processing, email delivery, dashboard infrastructure) — bound by confidentiality and data handling obligations
  3. Where required by law, court order, or legal proceedings
  4. To protect our legal rights, safety, or property
  5. In the event of a transfer or sale of the business, subject to equivalent privacy protections

Data Storage & Security

Personal information is stored using enterprise-grade hosting infrastructure (Netlify and our authenticated database provider), with encryption in transit (HTTPS) and at rest. Access is controlled through authenticated login systems with role-based permissions.

We take reasonable precautions to protect your personal information from loss, misuse, unauthorised access, modification, or disclosure. Prior to the deployment of any corporate engagement, the dashboard architecture undergoes independent security review by an Australian-accredited cybersecurity consultant.

No internet transmission or electronic storage can be guaranteed as fully secure. In the event of a data breach, we will notify affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme.

Data Retention & Deletion

Personal information is retained only for as long as necessary to fulfil the purposes for which it was collected, or as required by law (typically seven years for financial records under Australian taxation law).

You may request deletion of your personal information at any time by emailing kemina@coherencelaboratory.com. We will action verified requests within 30 days, subject to any legal obligations requiring retention.

International Data Transfers

The Coherence Lab is based in Australia. Where data is processed by service providers located outside Australia (such as Stripe for payments), we ensure those providers have privacy protections substantially equivalent to the Australian Privacy Principles.

If you are located in the European Union or United Kingdom, your data may be transferred to and stored in Australia. We implement appropriate safeguards consistent with the GDPR and UK Data Protection Act 2018.

Your Rights

You have the right to:

  1. Request access to the personal information we hold about you
  2. Request correction of inaccurate or incomplete data
  3. Request deletion of your personal information
  4. Withdraw consent for marketing communications at any time
  5. Lodge a complaint with the Office of the Australian Information Commissioner (OAIC) or other relevant supervisory authority

To exercise any of these rights, please contact us using the details below.

Newsletter & Marketing

If you subscribe to our newsletter, you may unsubscribe at any time by clicking the "unsubscribe" link in any email, or by contacting us directly. We will never send unsolicited marketing communications.

Children

Our services are intended for adults only. We do not knowingly collect personal information from anyone under the age of 16. If you believe a minor has provided us with personal information, please contact us and we will delete it promptly.

Changes to This Policy

We may update this Privacy Policy from time to time. The effective date at the top of this page will reflect any changes. Where changes are material, we will notify current clients directly.

Contact

Kemina Fulwood, Director

The Coherence Lab Pty Ltd

Fingal Head, NSW 2478, Australia

kemina@coherencelaboratory.com

+61 400 565 116

Agreement to Terms

By engaging with the programs or services offered by The Coherence Lab Pty Ltd (ACN [TO BE INSERTED]) ("The Coherence Lab", "we", "us") — including but not limited to the Sovereign Self System, The Before, the Coherence Map, the Coherence Profile, and the Leadership Coherence Cohort — you agree to be bound by these Terms of Service.

These Terms apply to all clients of The Coherence Lab, whether engaging directly or through a corporate engagement partner.

Nature of Services

The Coherence Lab provides nervous system intervention and leadership performance methodology. These services are not a substitute for medical treatment, psychiatric care, or psychological therapy.

If you are experiencing a mental health crisis, acute psychiatric condition, or require urgent medical attention, please contact an appropriate health professional or emergency service (Lifeline 13 11 14 or 000).

By engaging with our services, you confirm that you are in a stable enough state to participate in intensive personal and professional development work.

Application & Acceptance

All programs are offered by application or by referral. Acceptance into any program is at The Coherence Lab's sole discretion. If your application is not accepted, any payment made will be refunded in full.

Individual Client Engagements

Payment: Payment terms are confirmed at the time of acceptance into a program. Where payment plans are available, all instalments must be completed regardless of whether you choose to continue participation in the program. Payments are processed securely through our third-party payment providers. We do not store full payment card details.

Refund policy:

  1. Sovereign Self System: A full refund is available if you withdraw before your first session. After the first session has taken place, no refund is available. If The Coherence Lab is unable to continue for any reason, a pro-rata refund will be provided for unused sessions.
  2. Leadership Coherence Cohort: A full refund is available if you withdraw more than 14 days before the cohort start date. No refund is available after that point. If the cohort does not proceed, a full refund will be provided.
  3. Coherence Map and Coherence Profile: No refund once the Map has been delivered or the Profile has been completed.

Refund requests should be directed to kemina@coherencelaboratory.com

Rescheduling and cancellation: a minimum of 24 hours notice is required to reschedule a 1:1 session. Sessions cancelled with less than 24 hours notice may be forfeited. Genuine emergencies will be approached with discretion.

Corporate Engagements

Where you are engaged with The Coherence Lab through a corporate engagement partner (such as Hoffmann Reed Transformation Advisory), the following additional terms apply alongside the partner's separate Master Supplier Services Agreement with The Coherence Lab.

Dashboard visibility: your engagement progression will be visible to authorised representatives of the engagement partner organisation, limited to threshold progression, session attendance, and engagement markers. Session content and Coherence Profile detail will NOT be shared with the partner organisation without your explicit written consent. Any biometric or wearable data you choose to integrate via the dashboard is entirely optional, visible only to you and your assigned practitioner, and is never shared with the partner organisation.

Client Engagement Agreement: prior to commencing any corporate engagement, you will be asked to sign a Client Engagement Agreement that sets out the specific scope, confidentiality framework, and data handling arrangements applicable to your engagement.

Independence of practitioner relationship: the relationship between you and your assigned practitioner is independent of your relationship with the corporate engagement partner. The Coherence Lab will not act as a reporting line into your employer, sponsor, or partner organisation.

Confidentiality

All session content is strictly confidential. In group cohort settings, all participants are required to maintain confidentiality regarding the personal disclosures of other members.

The Coherence Lab reserves the right to share anonymised, general insights for educational or marketing purposes, without identifying any individual client.

Intellectual Property

All materials, frameworks, processes, methodologies, dashboards, applications, and content created and shared by The Coherence Lab — including the Sovereign Self System, the Coherence Profile, the Coherence Map, and the Coherence Deck — remain the intellectual property of The Coherence Lab Pty Ltd. They may not be reproduced, taught, recorded, or commercialised without prior written permission.

Outcomes

While The Coherence Lab is committed to providing high-quality professional services, we cannot guarantee specific outcomes. Results vary between individuals based on engagement, life circumstances, and other factors outside our control.

Limitation of Liability

To the extent permitted by Australian law, The Coherence Lab's liability for any claim arising from our services is limited to the amount paid for those services. Nothing in these Terms limits any liability that cannot be excluded by law, including under the Australian Consumer Law.

Governing Law

These Terms are governed by the laws of New South Wales, Australia. Any disputes will be subject to the exclusive jurisdiction of the courts of New South Wales.

Changes to These Terms

We reserve the right to update these Terms at any time. Current clients will be notified of any material changes. The effective date shown on this page reflects the most recent revision.

Contact

Kemina Fulwood, Director

The Coherence Lab Pty Ltd

Fingal Head, NSW 2478, Australia

kemina@coherencelaboratory.com

+61 400 565 116

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