Culture Wise Coaching privacy policy

Effective date: 1 November 2026

This policy explains how Culture Wise Coaching collects, uses, stores and shares personal information through our website, enquiries, coaching, programs, workshops and online communities. It also explains how to ask a question, request access or correction, or raise a privacy concern.

Who we are

Culture Wise Coaching is operated by Rebecca Louise Cosgrove trading as Culture Wise Coaching, ABN 67 070 732 279, based in Brisbane, Queensland. In this policy, “we”, “us” and “our” mean that business.

For privacy questions, contact Bec at [email protected].

Information we collect

The information we collect depends on how you work with us. It may include:

  • Your name, email address, phone number, organisation, role and contact preferences.

  • Enquiry, registration, enrolment, booking, attendance and program participation details.

  • Billing details, invoices and payment or transaction information relevant to your purchase.

  • Information you share in coaching, forms, messages, community posts, feedback or resources, including your goals and workplace situations. We may also keep coaching notes.

  • Your image, voice, displayed name and contributions in recorded sessions, and transcripts or summaries. Shared screens and chat may also be captured, depending on the session and settings.

  • Technical and activity information from our website and platforms, such as device or browser details, IP address, pages viewed and registration activity, depending on the tools in use.

  • Before You Speak account records, conversation history, generated responses, saved plans, reflections and memory summaries.

Please share only what is needed. Remove names and identifying details from examples about employees, clients and other people. Removing a name alone may not prevent someone being identified from their role, organisation or circumstances.

Our services focus on leadership and workplace coaching, not medical treatment or therapy. Sensitive information, such as health details, may still come up. Please avoid sharing it unless it is genuinely needed. Where we need to collect sensitive information, we will explain why and seek consent where required.

How we collect and use information

We generally collect information directly from you when you enquire, register, purchase, book, attend a session, complete a form or use our communities and resources. We may also receive information from an employer or person arranging a program for you, a referral, a payment provider, or the platforms used to deliver the service. Website technologies may collect information automatically.

We use relevant information to respond to enquiries, manage bookings and enrolments, deliver and support coaching and learning, provide resources and replays, process payments, keep business records, improve our services and manage privacy, security or legal matters. We use contact details for marketing only where we have the necessary permission.

You can make a general enquiry without providing more identifying information than necessary. For services such as enrolment, payment or individual coaching, we may need particular details to provide the service. If you do not provide them, we will explain any practical limitation.

Services and people we share information with

We use external providers to run the business and deliver services. Relevant information is handled through these services according to how they are used:

  • Ivorey for contact records, forms, sales pages and email or SMS communication. It has also been used for course content.

  • Stripe and PayPal for payments. We receive transaction information needed to administer purchases.

  • Skool for the CW Leadership Collective community and course access.

  • Zoom for online sessions, Fathom for meeting recording, transcription and summaries, and Descript for video editing.

  • Notion for client dashboards and notes, Outlook for email, Google Drive and Calendar for files and scheduling, and AI assistants such as OpenAI’s ChatGPT to help prepare notes and documents.

  • Netlify for website hosting, Meta for advertising and registration tracking, and Base44 for hosting and operating Before You Speak and providing its AI capabilities.

Providers may handle information on our behalf and, for some activities, for their own purposes under their terms and privacy policies. Giving a provider access does not remove our responsibility for the information we handle.

We may share relevant information with authorised people helping deliver or administer the service, professional advisers, or authorities where required or permitted by law.

An employer paying for coaching does not receive access to session recordings or group replays.

Communities and session recordings

Information you post in an online community may be visible to other members of that community.

We ask members to respect each other’s privacy and not copy or share other people’s contributions outside the group. We cannot guarantee what another participant may do, so please avoid posting confidential or identifying workplace information.

Our sessions are recorded to support session notes, and Bec advises participants at the start of the session. Group recordings are also shared as replays with participants in that group. Bec retains one-to-one coaching recordings and provides the client with session notes. Clients can request their own recording where it remains available. Employers do not receive access to these recordings or replays. Recordings may capture names, voices, images, chat and shared screens. Turning a camera off does not necessarily prevent other contributions being recorded.

Identifiable recordings, images, quotes or testimonials will not be used for public marketing without separate permission for that use.

Before You Speak and AI supported tools

Before You Speak, or BYS, is an AI-supported app operated by Culture Wise Coaching using Base44. It processes information you enter and relevant stored context to generate responses and support conversation preparation. The AI provider used for a response may vary.

BYS stores account and access information, conversation history, session information, plans, reflections and memory summaries. Memory features retain context for later responses. Bec can access administrative records and saved memory summaries through the app’s management tools.

BYS app data is stored in the United States and may be processed elsewhere. Base44 states that data on non-Enterprise plans, including the plan currently used for BYS, may be used to train AI models. This does not mean that a particular conversation has been used for training.

Ending app access does not automatically delete stored information. Some information cannot be deleted through the app dashboard and may require assistance from the provider. You can contact Bec about access, correction or deletion.

Do not enter identifiable employee, client or other third-party information, confidential workplace information, or sensitive personal information into BYS. Use fictional or appropriately de-identified examples instead.

We use AI-supported tools, including Fathom and ChatGPT, to assist with transcripts, summaries, notes and documents. Information handling depends on the provider, features and account settings; we do not make a blanket claim that information is never used to train or improve AI models.

Website technology and marketing

Our workshop registration page uses Meta advertising and a registration tracking pixel. This can send website activity and technical information to Meta for advertising measurement. That information may be linked with other information Meta holds.

Cookies and similar technologies may be used by the website, embedded services and platforms. You can manage cookies through your browser and advertising preferences through the relevant platform, although these controls may not stop every type of data collection and some features may be affected.

You can use the unsubscribe option in marketing emails or SMS, or contact Bec to opt out. We handle opt-outs within applicable legal timeframes. We may still send messages needed to deliver a service you requested, such as invoices, access information or schedule changes.

This policy does not itself provide consent to marketing or tracking.

Overseas information handling

Some service providers and their support teams or subprocessors are outside Australia, so information may be stored, accessed or processed overseas. Fathom identifies the United States as a storage location. BYS app data is stored in the United States. Base44 also lists service providers in the United States, Israel, Germany and the United Kingdom; the providers involved depend on the services and functions used.

Where applicable, we take reasonable steps required by law in relation to overseas disclosures. Using our services does not, by itself, waive any protections that apply to your personal information.

Storage security and retention

We take reasonable steps to protect personal information against misuse, interference, loss and unauthorised access, modification or disclosure. No online system or method of transmission is completely secure.

We retain personal information for as long as reasonably necessary to provide our services and meet applicable legal obligations. When it is no longer needed, we take reasonable steps to securely delete or de-identify it.

Requirements can differ between types of records. Ending program or app access is separate from deleting records. Copies in provider systems and backups may be subject to their retention and deletion processes.

Access correction and privacy concerns

Email [email protected] to ask for access to personal information we hold about you, request a correction, discuss deletion or raise a privacy complaint. Tell us what you need and how we can contact you. We may need to verify your identity without collecting more information than necessary.

We will review the request, respond within a reasonable time and explain the outcome or any next steps. Access may be limited where an applicable exception allows it, including to protect another person’s privacy. We may need to retain information despite a deletion request, for example for legal recordkeeping or a dispute. If we cannot meet a request, we will explain the reason where we can and discuss any available alternative. We will explain any proposed access charge in advance. This policy does not limit rights available under applicable law.

For a complaint, Bec will review the concern, seek further information if needed and provide a response explaining the outcome and any proposed action. If you are not satisfied, you can contact the Office of the Australian Information Commissioner at oaic.gov.au about its complaint process and whether it can consider the matter. Its jurisdiction depends on the applicable law.

Changes to this policy

We may update this policy when our services, systems or practices change. The current version will show its effective date. You can ask Bec for a copy by email.