PRIVACY POLICY

Last updated May 13, 2026

This Privacy Notice for Thrive With Sam Brincat ("we", "us", or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Visit our website at https://thrivewithsam.org or any website of ours that links to this Privacy Notice
Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at sam.brincat@thriveprogramme.org.

SUMMARY OF KEY POINTS

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at sam.brincat@thriveprogramme.org.

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include: names, phone numbers, email addresses, mailing addresses, billing addresses, debit/credit card numbers, and contact or authentication data.

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by Stripe. You may find their privacy notice at https://stripe.com/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for the following reasons:

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

The GDPR and UK GDPR require us to explain the valid legal bases we rely on to process your personal information:

Consent. We may process your information if you have given us permission to use your personal information for a specific purpose.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Australia and the United Kingdom. Your information may also be transferred to and processed in the United States. We will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

We have implemented the European Commission's Standard Contractual Clauses for transfers of personal information. Our Standard Contractual Clauses can be provided upon request.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet can be guaranteed to be 100% secure. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years of age. If you become aware of any data we may have collected from children under age 18, please contact us at sam.brincat@thriveprogramme.org.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your location, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to request access and obtain a copy of your personal information, to request rectification or erasure, to restrict the processing of your personal information, and to data portability.

If you have questions or comments about your privacy rights, you may email us at sam.brincat@thriveprogramme.org.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference. We do not currently respond to DNT browser signals as no uniform technology standard for recognising and implementing DNT signals has been finalised.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of certain US states, you may have the right to request access to and receive details about the personal information we maintain about you.

Depending on the state where you live, you may have rights including the right to know, access, correct, or delete your personal information, and the right to non-discrimination for exercising your rights. To exercise these rights, please contact us at sam.brincat@thriveprogramme.org.

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint to the Office of the Australian Information Commissioner.

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top of this Privacy Notice. We encourage you to review this Privacy Notice frequently.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at sam.brincat@thriveprogramme.org or contact us by post at:

Thrive With Sam Brincat
15 The Avenue
Caroline Springs, 3023
Australia

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please contact us at sam.brincat@thriveprogramme.org.

This Privacy Policy was created with the assistance of Termly's Privacy Policy Generator.