AVENIR Group Pty Ltd Privacy Policy

Our commitment to privacy

AVENIR Leadership Group respects and values our clients, partners, and community members. We are committed to managing your personal information responsibly and in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy outlines how AVENIR Leadership Group collects, stores, uses, and discloses your personal information, as well as how you can access or correct it. The policy does not apply to our employee records where exempt under the Privacy Act.

SCOPE AND DEFINITIONS

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Sensitive information is a subset of personal information and includes details such as health or genetic information, racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation or practices, trade union membership, criminal record, and certain biometric information.

WHAT KINDS OF INFORMATION WE COLLECT

We collect only the personal information reasonably necessary for our business,

marketing, and reporting purposes. This may include:

• your name, email, postal address, phone number and other contact details;

• information associated with your interactions with us online (such as website activity, social media engagement, Kajabi account behaviour, or enquiries through our Squarespace forms);

• records of your interactions with us via phone, email (including Outlook), or social media;

• your preferences about communication methods and topics of interest;

• responses to surveys, feedback forms, or research we conduct.

Depending on our interactions, additional information may be collected, including payment details for event registrations or service invoices; demographic or professional information (e.g. job title, organisation, industry) for business development purposes; photos, audio, or video recordings from events or training sessions (with consent); information provided in applications for employment, partnerships, or collaborations.

You may choose not to provide certain details; however, this may limit our ability to deliver specific services or communications.

HOW WE COLLECT PERSONAL INFORMATION

We usually collect personal information directly from you when you:

• sign up for a course, event, or newsletter via Kajabi or our Squarespace website;

• communicate with us via Outlook email, web forms, or SMS;

• engage with our social media or marketing campaigns; or participate in business development activities, surveys, online training, or consultations.

We may also collect information from publicly available sources or third parties when you have given consent. Sensitive information will only be collected with your explicit permission, except as otherwise allowed by law.

WHY WE COLLECT AND USE YOUR PERSONAL INFORMATION

We collect and use your personal information to operate efficiently, enhance our services, and improve your experience. We may use your information to verify your identity; deliver and manage our leadership programs, courses, or events; send updates, materials, and insights related to our services; conduct marketing and business development activities; generate internal reports and analytics to evaluate engagement and program outcomes; process payments and issue receipts or invoices; evaluate feedback and conduct research to improve offerings; manage governance, risk, and compliance obligations; and meet applicable legal and regulatory requirements. You may choose to interact with us anonymously or through a pseudonym when lawful and practicable (for example, when making a general enquiry). However, most of our services require identifiable information to function properly.

ONLINE INTERACTIONS

When visiting our website (https://www.avenirgroup.com.au), you may choose to identify yourself. If you do, any personal data collected will be handled according to this policy.

Our websites use cookies and tracking pixels to:

• monitor website usage, audience behaviour, and campaign performance;

• customise online experiences and advertising relevant to your interests; and analyse activity through platforms such as Google Analytics, Kajabi and Squarespace.

You can modify your browser settings to manage or block cookies, but doing so may limit site functionality. Our site may link to third-party websites, and we are not

responsible for their privacy practices. We also use secure authentication to protect your member accounts or purchased program access through Kajabi.

AUTOMATED DECISION-MAKING AND PROFILING

We use analytics and segmentation to understand engagement and tailor content. We do not rely on automated decision-making that is likely to significantly affect your rights or interests. If this changes, we will update this policy and provide clear information about the types of automated decisions involved and how you may contest or seek human review.

HOW WE STORE AND PROTECT PERSONAL INFORMATION

Personal information is stored in secure databases and electronic systems, including Kajabi, Squarespace, and Outlook. Data may reside in trusted third-party storage providers hosted in Australia or overseas. We take reasonable steps to protect all personal data from misuse, unauthorised access, alteration, or disclosure through SSL encryption on sensitive data transfers; password protection, access controls, and secure authentication systems; and established retention and destruction policies to delete or de-identify data that is no longer required.

DATA RETENTION

We retain personal information only for as long as needed to fulfil the purposes described in this policy or as required by law. When personal information is no longer needed, we take reasonable steps to delete or de-identify it, unless retention is required by law or a court/tribunal order.

MARKETING AND COMMUNICATIONS

We may use your personal information for marketing AVENIR Leadership Group’s services, programs, and events that we believe may interest you. You can opt out at any time using the unsubscribe link in our communications, or by contacting us directly. Even if you opt out of marketing, we may still contact you about your ongoing relationship with us, such as event updates or required service communications. If you ask, we will tell you where we obtained your contact details, unless it is impracticable or unreasonable to do so.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your personal information to trusted third parties who help us operate our business, such as:

• data storage, processing, and analysis providers (including Kajabi and Squarespace);

• IT support, email, and communications platforms (such as Outlook);

• marketing, advertising, or analytics providers;

• event or training management providers;

• and professional advisers such as accountants, insurers, or lawyers.

We require these third parties to use your information only for the purpose for which it was disclosed and to comply with applicable privacy laws. We may also share your personal information when required by law or to manage legal claims and obligations.

OVERSEAS DISCLOSURE

Some data storage providers or service platforms we use may host or process information in countries such as the United States, Singapore, or other locations. Before disclosing personal information overseas, we take reasonable steps to ensure recipients will handle your information in accordance with standards that are substantially similar to the APPs, including through contractual safeguards and due diligence.

When we collect personal information in the United States of America (USA), we align with the California Consumer Privacy Act (CCPA). When we collect personal information in the European Union (EU) or the United Kingdom of Great Britain and Northern Ireland (UK), we comply with the EU General Data Protection Regulation (EU GDPR) and the UK General Data Protection Regulation (UK GDPR). These frameworks provide additional rights and protections for individuals in those jurisdictions, and we will honour those obligations where applicable.

CHILDREN’S PRIVACY

Where our services involve minors, we take additional care with collection and consent. We assess capacity to consent case by case and may seek consent from a parent or guardian where appropriate. We design notices and communications to be age-appropriate and avoid targeted marketing to children without appropriate safeguards.

ACCESS, CORRECTION, AND DELETION

You have the right to access and request correction or deletion of your personal information. Requests can be made by contacting our Privacy Officer using the details below. We will respond within a reasonable period (usually within 30 days) and, if we refuse a request, we will provide written reasons and information about complaint mechanisms. We do not charge for correction requests. Where deletion is requested and permitted, records will be securely erased or de-identified.

DATA BREACH NOTIFICATION

If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme. Our response plan includes assessing the incident, containing and remediating risks, and communicating recommended steps you should take.

COMPLAINTS AND CONCERNS

If you have a concern or complaint about how your personal information has been handled, please contact: Jon Bergmann (Privacy Officer – AVENIR Group), Email:

jon@avenirgroup.com.au We aim to acknowledge all complaints within one week and, where necessary, investigate and respond within 30 days. If you are dissatisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at

www.oaic.gov.au or by phone at 1300 363 992.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be amended from time to time. Updates will be published on our website, and the latest version will always be available online. This version supersedes all previous versions.

Last updated: December 2025

Version: 1.1