Last updated: 28 August 2025
We care about your privacy and believe in being upfront. This Privacy Policy explains what we collect, how we use and share it, and the choices you have. It also explains how content you choose to share in Public Areas of the Community may be used in our marketing and promotions.
This Privacy Policy works together with our Terms of Service (the “Terms”). Capitalised words not defined here have the meaning given in the Terms.
If we make material changes, we’ll update the date above and, where appropriate, let you know.
Proganics Pty Ltd (“Proganics”, “we”, “us” or “our”) operates the Proganics Wellness Hub (the “Community”). Our Community is hosted on technology provided by CircleCo, Inc. (“Circle”).
Contact: [email protected]
Address: Unit 3 / 53 Riverside Place, Morningside QLD 4170, Australia
References to “Proganics” include successors and assigns (for example, if our business is transferred to a family trust).
We collect information you give us (e.g., account details, posts, messages), information we get automatically (e.g., device and usage data, cookies), and information from partners.
Marketing Spaces: When you submit content in spaces clearly identified as being for testimonials, reviews, success stories, campaigns, or similar marketing collection (“Marketing Spaces”), you authorise us to use that content for our marketing as described below.
Public Areas: If you post in Community areas visible to other members or the public (the “Public Areas”), you give us a broad, friendly licence to reuse that content in our marketing and promotions.
We only use sensitive information (such as health or weight) in marketing with your explicit consent.
You can manage your preferences (email/SMS/push), request access or correction, and ask us to stop using your content for future marketing.
We take reasonable security measures, use service providers (including Circle), and transfer data internationally.
To the maximum extent permitted by law, we’re not responsible for what you choose to make public, for other members’ actions, or for third-party services.
Public Areas: Any part of the Community where your content can be seen by other members or, where applicable, by the general public (e.g., feed, groups, comments, challenges, leaderboards, or pages marked “Public”).
Private Areas: Direct messages and account or billing pages not visible to other members.
Marketing Spaces: Forms, posts, prompts, surveys, or areas clearly labelled or reasonably understood to collect content for marketing (e.g., “Testimonials”, “Before & After”, “Success Stories”, “Reviews”, “Feature Me”, “Share My Journey”, campaign application forms).
Sensitive information: Things like health information, weight, measurements, medical conditions, or dietary restrictions.
Information you provide:
Registration & profile (e.g., name, email, display name, photo, bio).
Content you share (e.g., posts, comments, photos, videos, reactions).
Messages between members (we receive the content and metadata needed to provide the service and for safety/moderation).
Forms & submissions (including in Marketing Spaces, surveys, competitions, promotions).
Coaching sessions: Information you share during 1:1 coaching sessions or group support may be recorded in our system to support your ongoing participation. Such information is handled in line with this Privacy Policy and is not considered medical records or health records.
Support & communications (emails, chat messages, feedback).
Payments: Payment details are collected and processed by our third-party payment processor on our behalf (we don’t store full payment card numbers).
Information collected automatically:
Device & log data (IP address, device identifiers, browser type, operating system, referring/exit pages, clicks, pages viewed, session duration).
Usage data (how you use the Community, links you click, ads you view or interact with, videos watched, checkout events).
Approximate location (derived from IP address or your entries such as postcode).
Cookies and similar technologies (we and our partners use cookies, pixels and tags for analytics, Community performance, and marketing).
Information from third parties:
Social platforms (if you connect or sign in with them).
Marketing/analytics partners (e.g., campaign performance, audience insights).
Other members (if they share or mention information about you in Public Areas).
In some cases, you may choose to provide health-related information (such as weight, measurements, dietary preferences, or medical considerations). This is considered sensitive information under the Privacy Act 1988 (Cth). We only collect and use this information with your consent and where reasonably necessary to provide the Community’s services (for example, coaching, accountability check-ins, or personalised resources).
We use your information to:
Provide, maintain and improve the Community and your experience.
Personalise content and features.
Process transactions and provide support.
Communicate with you about the Community, updates, security alerts, and administrative matters.
Marketing & promotions: communicate about our products, services, offers, events and content we think you’ll like; create audience segments; run interest-based advertising and measurement; build lookalike audiences (including by sharing hashed contact identifiers with advertising platforms); and publish testimonials or success stories as described below.
Analyse content using automated tools, including artificial intelligence (AI) services, to provide educational insights, nutrition feedback, or improve our services. These tools may process content you submit (such as food photos, check-in data, or text entries). We use trusted third-party vendors and take reasonable steps to ensure they protect your information.
Monitor and understand trends, usage and performance.
Detect, investigate and prevent fraud, abuse and safety incidents; enforce our Terms.
Combine information we have to better understand your needs and improve our service.
Carry out any purpose disclosed to you when you provide the information or as permitted by law.
Legal requests, safety & defamation complaints. We use your information to:
Operate an accessible complaints mechanism for unlawful, defamatory, or harmful content.
Assess and action complaints (including temporarily hiding or removing content and restricting accounts).
Notify posters about complaints and share complaint details with them where appropriate.
Keep records of complaints, our decisions, and timing of any access-prevention steps.
Cooperate with regulators (including the eSafety Commissioner) and law enforcement where required.
We implement this to comply with Australian online safety and defamation frameworks and to keep members safe.
International takedown. We accept and assess complaints from any jurisdiction and may restrict access by location while we assess, particularly where criminal defamation may apply (e.g., Colombia, Chile).
AI assistance & moderation. We use AI tools (including “Coach Bailey AI”) and human reviewers to generate educational content, assist with responses, and surface safety risks. AI may analyse posts, comments, and images to provide guidance or flag potential issues. AI outputs may be inaccurate and are not medical advice. Automated tools do not create a duty to monitor; we act reasonably when notified. Official statements are those we expressly designate.
When you submit content in a Marketing Space, you authorise us to use, reproduce, edit for length/clarity, publish, display, distribute and communicate that content for our marketing and promotional purposes in any media now known or later developed (for example our websites, Community, emails, social media, ads, case studies, press), worldwide and without payment.
Where the content includes sensitive information, we will only use it for marketing with your explicit opt-in consent at submission (e.g., a tick-box or written “yes”). You can withdraw your consent for future uses at any time (see Your choices), but this won’t affect content already published or in production at the time we process your request.
When you post or otherwise make content available in a Public Area, you grant Proganics a non-exclusive, worldwide, royalty-free, sublicensable and transferable licence to use, reproduce, adapt, publish, translate, create derivative works from, distribute, publicly perform and publicly display that content (and your display name and profile photo as it appears with the content) for our marketing, promotional and Community purposes in all media.
If the content includes sensitive information or your image is used in a way that clearly focuses on you (e.g., a feature story), we will only use it for marketing with your explicit consent.
We may make reasonable edits for clarity, length or formatting, and we’ll aim to represent you fairly and respectfully.
If you would like us to stop using your Public Area content for future marketing, let us know (see Your choices). This won’t affect materials already created or published.
Important: You are responsible for the content you share. By posting, you confirm you have the right to share it (including any photos/videos) and that anyone identifiable in your content consents to its sharing and potential marketing use as outlined above.
Please note: once you share information in Public Areas, we cannot control how other members may use, copy, or distribute it. We strongly encourage you not to post personal health information you do not want shared more widely.
You must ensure your content is lawful and not defamatory. You warrant you have all rights needed to post it and you indemnify us for losses arising from claims about your content.
Some Community or marketing content may be prepared by our team or with AI/ghostwriting assistance. Official statements are those we expressly designate.
We may disclose information to:
Circle (platform provider) to operate and support the Community.
Service providers and vendors (e.g., hosting, analytics, payment processing, customer support, email/SMS, advertising).
Marketing and advertising partners (including social platforms) for audience creation, ad delivery and measurement - sometimes by sharing hashed contact identifiers.
Affiliates and related entities for the purposes in this policy.
Other members and the public when you post in Public Areas.
Law enforcement or regulators where required or permitted by law or to protect rights, safety and security.
Business transactions (e.g., merger, acquisition, financing or sale of assets).
With your consent or at your direction.
Complainants and posters: If a defamation or legal complaint is made about your content, we may share your display name, the content complained of, timestamps, and our decision with the complainant and with you.
Regulators/courts: Where required or permitted by law, we may share complaint files, moderation records, and logs with the eSafety Commissioner or a court/tribunal.
Platform provider (Circle): We may share limited complaint metadata with Circle solely to investigate platform abuse or to implement access-prevention steps.
Brand/interest spaces: We may enable spaces discussing third-party brands. We are not affiliated with those brands unless we say so. If a rights holder raises concerns, we may restrict access or remove content while we assess.
We are not responsible for how other members use information you choose to make public. Please be mindful about what you share.
We prohibit abuse, hate, threats, illegal activity, and exploitation. We also prohibit unlawful vilification and using the Community to menace or harass. We may remove content without notice where we reasonably believe it breaches our rules or law, and we may refer serious matters to police.
This includes threats, harassment, vilification, hate speech, terrorism content, child sexual exploitation, and trading in prohibited items (weapons, drugs, etc.).
If you see something harmful or unlawful, please use the Report tool or email [email protected].
Complaints are handled in line with our Community Standards & Takedown Policy: https://wellness.proganics.au/community-standards-and-takedown-policy
We are an Australian company. The Community is hosted in the United States, and we may transfer information to the United States and to other countries where we and our service providers operate. We take reasonable steps to ensure overseas recipients protect your information in a way that is substantially similar to the Australian Privacy Principles.
By using the Community, you consent to these transfers. If you are in the EEA/UK, we rely on appropriate safeguards (such as Standard Contractual Clauses) where required.
We keep personal information for as long as needed to provide the Community, comply with legal obligations, resolve disputes, support audits, and pursue our legitimate business interests. We may retain archival copies (e.g., backups, moderation records). Content already used in published marketing may be retained as part of those materials and our records.
We use reasonable technical and organisational measures designed to protect the information we hold. However, no method of transmission or storage is perfectly secure. To the maximum extent permitted by law, we are not liable for unauthorised access or use that is beyond our reasonable control.
Account & profile: Update certain details any time in your account. To request deletion or deactivation, email [email protected]. We may retain information as required by law or for legitimate purposes (see Data retention).
Marketing emails: You can unsubscribe using the link in our emails. You’ll still receive essential (non-marketing) messages.
SMS (texts) & phone: By providing your mobile number, you consent to receiving SMS and calls (including marketing) from us. Message and data rates may apply. Reply STOP to SMS to opt-out; reply HELP for help.
Push notifications: Turn these on/off in your device settings.
Cookies & interest-based ads: You can manage cookies in your browser and device settings. You may also see ad preference tools offered by major platforms. If you disable cookies, some features may not work as intended.
Public Area/Marketing Space content: You can ask us to stop using your content for future marketing by contacting [email protected]. This won’t affect materials already created, distributed, or committed to production at the time we process your request.
Access & correction: You may request access to, or correction of, the personal information we hold about you.
Sensitive information in marketing: We only use sensitive information in marketing with your explicit consent, which you can withdraw for future uses at any time.
We do not monitor member posts, messages, or health information for medical emergencies. If you require urgent medical attention, call 000 in Australia or your local emergency services.
The Community is not for individuals under 16 (or under 13 if located in the United States). If we learn we have collected personal information from someone under these ages, we’ll take reasonable steps to delete it. Please contact us if you believe this has occurred.
The Community may offer social sharing features and links to third-party sites and services. Their privacy practices are not controlled by us. Use of those services is at your own risk; please review their policies.
There’s no agreed industry standard on responding to “Do Not Track” signals, and we do not respond to them.
Australia: We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. You may contact us with privacy questions or complaints at [email protected]; we’ll respond and, if unresolved, you may contact the OAIC.
EEA/UK (where applicable): We process personal data as needed to perform our contract with you, based on our legitimate interests (e.g., to operate and improve the Community), to comply with legal obligations, and with your consent (e.g., for certain marketing and any use of sensitive information in marketing). You may have rights to access, correct, delete, or object to certain processing; to withdraw consent; and to data portability.
United States: We may engage in interest-based advertising and share hashed identifiers with advertising platforms for ad delivery and measurement.
Nothing in this Policy limits your rights under the Australian Consumer Law. Subject to those rights and to the maximum extent permitted by law, members are responsible for what they post. Proganics is not responsible or liable for:
information you choose to make public;
the actions of other members or third parties;
third-party services or platforms;
AI outputs, moderator opinions, or ghostwritten content not expressly designated official;
redistribution of Community content (e.g., screenshots, recordings) by third parties; or
events beyond our reasonable control.
The Terms of Service, the Community Standards & Takedown Policy, and the Health & Wellness Disclaimer (Exhibit A) govern your use of the Community. These documents include medical disclaimers, acceptable use rules, notice-and-takedown procedures, indemnities, and liability limits. If there is any conflict between this Privacy Policy and those documents, the Terms, Standards and Disclaimer will prevail.
Questions or requests about this Policy or your information: [email protected]
Postal: Proganics Pty Ltd (Proganics Wellness Hub)
Unit 3 / 53 Riverside Place, Morningside QLD 4170, Australia