Effective Date: | Version: 1.0
Governing Law: Australia |
1. Introduction and Our Commitment
The Lifestyle Club Pty Ltd (TLC24 Coaching) ("we," "us," or "our") is an Australian fitness, nutrition, and lifestyle coaching and education business. We provide personalised meal plans, fitness programming, lifestyle advice, general health education, and supplement guidance to our clients.
We are committed to protecting your privacy and handling your personal information, including sensitive health information, with care, transparency, and respect. This Privacy Policy explains how we collect, use, store, disclose, and protect your personal information in accordance with:
• The Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained in Schedule 1;
• The Health Records and Information Privacy Act 2002 (NSW) and equivalent state legislation where applicable;
• The Spam Act 2003 (Cth) for electronic marketing communications;
• The Therapeutic Goods Act 1989 (Cth) as it relates to our supplement guidance; and
• Other applicable Australian laws and industry codes.
Note: Because we collect health and body composition data, a significant portion of the personal information we handle is classified as "sensitive information" under the Privacy Act 1988 (Cth). We take additional care to protect this category of information.
2. About Us
The Lifestyle Club Pty Ltd (TLC24 Coaching) is an Australian business providing fitness coaching, nutrition coaching, lifestyle education, and supplement recommendations. Our services are delivered online and/or in person.
Business Name
The Lifestyle Club Pty Ltd (TLC24 Coaching)
Country of Operation
Australia
Governing Privacy Law
Privacy Act 1988 (Cth) — Australian Privacy Principles
Phone
+61 468 015 117
Address
25 Bombala Street Broadbeach Waters Queensland 4218
3. What Personal Information We Collect
We collect personal information that is reasonably necessary to provide our fitness, nutrition, and lifestyle coaching services. The types of information we may collect include:
3.1 Identity and Contact Information
• Full name
• Date of birth
• Email address
• Phone number (including mobile)
• Residential or postal address
• Emergency contact details
3.2 Sensitive Health and Body Composition Information (APP 3 & APP 6)
This is classified as "sensitive information" under s 6 of the Privacy Act 1988 (Cth). We will only collect this information with your express consent, and it will only be used or disclosed for the purposes you consented to.
• Current body weight, height, and body measurements
• Body fat percentage and muscle mass data
• Physical fitness levels and exercise history
• Dietary preferences, restrictions, allergies, and intolerances
• Medical conditions relevant to fitness or nutrition (e.g. diabetes, cardiovascular conditions, musculoskeletal injuries)
• Prescription medications and supplements currently taken
• Hormonal health, menstrual cycle data (where relevant to programming)
• Sleep patterns and quality
• Mental health and stress levels (self-reported, as relevant to lifestyle coaching)
• Photographs or videos for progress tracking (with your explicit consent)
• Results from fitness assessments, movement screens, or body composition scans
3.3 Lifestyle and Behavioural Information
• Nutrition and dietary intake records (food diary data)
• Exercise and activity logs
• Lifestyle habits including sleep, alcohol intake, and smoking status
• Occupational activity level and daily step counts
• Stress and recovery indicators
3.4 Financial Information
• Payment card details (processed via secure third-party payment processors only — we do not store raw card data)
• Billing address
• Transaction history for services purchased
3.5 Digital and Technical Information
• IP address and device identifiers
• Browser type and version
• Pages visited on our website and time spent
• App usage data (where applicable)
• Cookie and tracking data (see Section 9)
3.6 Communications
• Emails, messages, and notes exchanged with your coach
• Feedback, testimonials, and survey responses (with your consent)
• Client check-in forms and progress reports
4. How We Collect Your Personal Information
Under APP 3, we collect personal information by lawful and fair means and, where reasonable, directly from you. We collect information in the following ways:
4.1 Directly From You
• Client intake and health questionnaires completed at onboarding
• Registration and account creation on our website or app
• Consultations, coaching sessions, and check-in calls
• Emails, SMS messages, or online forms
• Fitness assessments and body composition measurements
• Progress photographs (submitted with your consent)
• Food diary or training log submissions
4.2 From Third Parties (With Your Consent)
• Healthcare providers or allied health professionals (e.g. GPs, physiotherapists, dietitians), where you have authorised disclosure
• Connected wearable devices or fitness apps (e.g. Garmin, Apple Health, MyFitnessPal) where you authorise integration
• Referrals from other clients or professionals
4.3 Automatically
• Website cookies and analytics tools
• Email open and click tracking
• App usage logs (where applicable)
5. Why We Collect and Use Your Personal Information (APP 6)
We collect, hold, and use your personal information for the primary purposes for which it was collected, and related secondary purposes you would reasonably expect. These purposes include:
5.1 Service Delivery
• Designing and delivering personalised meal plans tailored to your goals, health status, and dietary requirements
• Creating individualised fitness programming, including strength, cardio, and mobility plans
• Providing general lifestyle coaching and education including sleep, stress management, and habit formation
• Making supplement recommendations appropriate to your goals and health profile (noting we do not prescribe medications and always recommend consulting a healthcare professional)
• Conducting regular check-ins, progress tracking, and plan adjustments
• Assessing readiness to exercise and flagging when a client should seek medical clearance
5.2 Safety and Duty of Care
• Identifying contraindications or risk factors before commencing exercise or dietary programs
• Monitoring client wellbeing and adjusting programming where health risks are identified
• Referring clients to appropriate healthcare professionals where necessary
5.3 Administration and Business Operations
• Processing payments and managing billing
• Maintaining client records and service history
• Sending appointment reminders, session confirmations, and service updates
• Managing complaints and feedback
5.4 Marketing and Communications (With Consent — Spam Act 2003)
• Sending educational content, newsletters, and health tips where you have opted in
• Promoting new programs, products, or services via email or SMS where you have provided consent
• Sharing client success stories or testimonials (only with explicit written consent, and with the option to remain anonymous)
5.5 Legal and Compliance
• Complying with our legal obligations under applicable Australian law
• Responding to regulatory inquiries or law enforcement requests
• Enforcing our terms and conditions and service agreements
We will not use your sensitive health information for marketing or advertising purposes without obtaining your separate, express consent.
6. Supplement Recommendations — Important Disclosure
The Lifestyle Club Pty Ltd (TLC24 Coaching) may provide general supplement education and recommendations as part of our lifestyle coaching services. It is important that clients understand the following:
• We are fitness and nutrition coaches, not registered pharmacists, medical practitioners, or dietitians (unless separately qualified and operating under those credentials).
• All supplement information we provide is general in nature and is based on publicly available research and our professional coaching experience.
• Supplement recommendations are not medical advice and do not constitute the practice of medicine or pharmacy.
• All supplements we recommend are, to the best of our knowledge, listed or otherwise compliant with the Therapeutic Goods Administration (TGA) requirements for sale in Australia.
• We strongly encourage all clients to consult with their GP, pharmacist, or an Accredited Practising Dietitian (APD) before commencing any supplement protocol, particularly if you have an existing medical condition, are pregnant or breastfeeding, or take prescription medications.
• Health information you share with us in relation to supplement suitability is treated as sensitive information and is handled in accordance with this Privacy Policy.
7. Disclosure of Your Personal Information (APP 6 & APP 8)
We do not sell, rent, or trade your personal information to third parties. We may share your information in limited circumstances, as set out below:
7.1 Service Providers (Contracted Processors)
We may share your information with trusted third-party service providers who assist us in operating our business, subject to strict confidentiality obligations. These may include:
• Cloud hosting and data storage providers (e.g. servers located in Australia or countries with adequate privacy protections)
• Payment processors (e.g. Stripe, Square) — who handle payment data under their own PCI-DSS compliant privacy policies
• Coaching or practice management software providers (e.g. exercise or nutrition tracking platforms)
• Email and SMS communication platforms
• Accounting and bookkeeping software
7.2 Healthcare Professionals (With Your Consent)
Where you consent, we may liaise with your GP, physiotherapist, dietitian, or other allied health professional to ensure your program is safe and appropriate.
7.3 Legal and Regulatory Obligations
We may disclose personal information where required by Australian law, a court order, or a request from a regulatory authority (e.g. the Office of the Australian Information Commissioner (OAIC), Australian Taxation Office, or law enforcement).
7.4 Business Transfers
If we sell or transfer part or all of our business, your personal information may be transferred as part of that transaction. We will notify you before this occurs and ensure the transferee is bound by obligations consistent with this Privacy Policy.
7.5 Overseas Disclosure (APP 8)
Some of our third-party service providers (e.g. cloud platforms) may store or process data outside Australia. Before disclosing your information to an overseas recipient, we take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your information. We will notify you in our service agreement if your data will be processed outside Australia and in which countries.
We do not share your mobile number or SMS opt-in data with any third parties for marketing or promotional purposes. SMS data is used solely to deliver service-related communications.
8. Electronic Marketing and SMS Communications (Spam Act 2003)
We may send you electronic communications, including email newsletters, educational content, promotional material, appointment reminders, and service updates. All electronic marketing is governed by the Spam Act 2003 (Cth) and the Australian Communications and Media Authority (ACMA) guidelines.
8.1 Consent
We will only send you marketing communications where you have provided express or inferred consent as defined under the Spam Act 2003 (Cth). Consent to receive communications is never a condition of purchasing our services.
8.2 SMS / MMS Communications
If you provide your mobile number and opt in, we may send you SMS or MMS messages including:
• Appointment reminders and scheduling notifications
• Program check-in prompts
• Service-related account updates
• Promotional or educational content (where you have separately consented)
8.3 Opt-Out / Unsubscribe
You may withdraw your consent to receive electronic marketing at any time, at no cost, by:
• Replying STOP to any SMS message;
• Clicking the unsubscribe link in any marketing email; or
• Contacting us directly at [email protected] or +61 468 015 117.
Unsubscribing from marketing communications will not affect service-related communications that are necessary to deliver your coaching program.
9. Cookies and Website Tracking
Our website uses cookies and similar technologies to improve your browsing experience, analyse site traffic, and understand how visitors use our site.
9.1 Types of Cookies We Use
• Essential / Session Cookies — required for the website to function correctly; deleted when you close your browser.
• Persistent Cookies — remain on your device after you close your browser and are used to remember your preferences on future visits.
• Analytics Cookies — help us understand how visitors interact with our website (e.g. Google Analytics). Data is aggregated and de-identified where possible.
• Marketing Cookies — used to track the effectiveness of our advertising campaigns (where applicable, and only with your consent).
9.2 Managing Cookies
You can manage or disable cookies through your browser settings. Please note that disabling essential cookies may affect the functionality of our website. For more information about cookies, visit www.allaboutcookies.org.
10. Data Quality, Storage, and Security (APP 11)
10.1 Data Quality (APP 10)
We take reasonable steps to ensure that the personal information we hold is accurate, up-to-date, complete, and relevant. We encourage you to notify us promptly of any changes to your personal information, particularly health information that may affect your coaching program.
10.2 Data Security (APP 11)
We implement commercially reasonable technical and organisational security measures to protect your personal information from misuse, loss, unauthorised access, modification, or disclosure. These measures include:
• Password protection and multi-factor authentication on systems that hold client data
• Encryption of data in transit (SSL/TLS) and at rest where feasible
• Limiting access to personal information to staff and contractors who need it to perform their role
• Confidentiality agreements with contractors and service providers
• Regular review of our data security practices
While we take these steps, no method of data transmission or storage is completely secure. We cannot guarantee absolute security, and we encourage you to contact us immediately if you believe your information has been compromised.
10.3 Notifiable Data Breaches (Privacy Act 1988, Part IIIC)
We are bound by the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). If we become aware of a data breach that is likely to result in serious harm to any individual whose information is involved, we will:
• Assess the breach promptly;
• Notify the Office of the Australian Information Commissioner (OAIC) as soon as practicable; and
• Notify affected individuals, providing them with information and advice about steps they should take.
11. Retention of Personal Information (APP 11.2)
We retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. In practice, this means:
• Client coaching records (including health information) are generally retained for a minimum of 7 years from the date of last service, consistent with Australian business and potential legal requirements.
• Financial records are retained for a minimum of 5 years in compliance with the Income Tax Assessment Act 1997 (Cth) and the Corporations Act 2001 (Cth) (where applicable).
• Where we collect health information from clients who are (or may be) minors, we retain records for a minimum of 7 years after the client turns 18, or 7 years from the date of the last service — whichever is longer.
• When personal information is no longer required, we will take reasonable steps to destroy or de-identify it securely.
12. Your Privacy Rights Under the Australian Privacy Principles
As an individual whose personal information we hold, you have the following rights under the Privacy Act 1988 (Cth):
12.1 Right to Access (APP 12)
You have the right to request access to the personal information we hold about you. We will respond to access requests within 30 days. We will provide access in a format that is practical for both parties. In some limited circumstances, we may be required by law to refuse access — if so, we will explain why in writing.
12.2 Right to Correction (APP 13)
You have the right to request correction of any personal information that is inaccurate, out-of-date, incomplete, or misleading. We will respond to correction requests within 30 days. If we refuse a correction request, we will provide written reasons.
12.3 Right to Complain
You have the right to make a privacy complaint if you believe we have mishandled your personal information. Please see Section 14 for our complaints procedure.
12.4 Right to Withdraw Consent
Where we rely on your consent to use your personal information (including sensitive health information), you may withdraw that consent at any time by contacting us. Withdrawal of consent may affect our ability to continue providing services.
12.5 Right to Anonymity (APP 2)
Where lawful and practicable, you have the right to deal with us anonymously or using a pseudonym. However, due to the nature of personalised coaching services, we may be unable to provide our full range of services without knowing who you are.
13. Children and Young People
Where we provide services to individuals under the age of 18, we require verifiable parental or guardian consent prior to collecting or processing their personal information. We do not knowingly collect personal information from individuals under 16 without parental consent.
If you are a parent or guardian and become aware that a minor has provided us with personal information without your consent, please contact us immediately.
14. Privacy Complaints Procedure
We take privacy complaints seriously. If you believe we have breached the Australian Privacy Principles or otherwise mishandled your personal information, please follow this process:
Step 1 — Contact Us Directly
Submit your complaint in writing to [email protected] or by post to 25 Bombala Street Broadbeach Waters Queensland 4218. Please include your name, contact details, and a description of your concern. We will acknowledge receipt of your complaint within 5 business days and aim to resolve it within 30 days.
Step 2 — Office of the Australian Information Commissioner (OAIC)
If you are not satisfied with our response, or if we fail to respond within 30 days, you may escalate your complaint to the OAIC:
• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our business practices, legal obligations, or the services we offer. When we make material changes, we will:
• Post the updated policy on our website with a new effective date;
• Notify active clients via email; and
• Where required by law, seek fresh consent for changes that affect how we use your sensitive health information.
We encourage you to review this Privacy Policy periodically.
16. Contact Us
For any questions, requests, or concerns regarding this Privacy Policy or the handling of your personal information, please contact us:
Privacy Officer / Contact
The Lifestyle Club Pty Ltd (TLC24 Coaching)
Phone
+61 468 015 117
Postal Address
25 Bombala Street Broadbeach Waters Queensland 4218
Response Time
Within 5 business days for acknowledgement; 30 days for resolution
© 2026 The Lifestyle Club Pty Ltd (TLC24 Coaching). This document is governed by the laws of Australia.
This Privacy Policy does not constitute legal advice. You should seek independent legal advice if required.