Last Updated: Feb 26th, 2026
Effective Date: Feb 26th, 2026
This Privacy Policy applies to services provided by:
Legal Entity: Spiritual Family Trust
Trading Name: Executive Warrior Academy
ABN: 22 860 118 393
Location: Sydney, New South Wales, Australia
Website: ExecutiveWarriorAcademy.com
Mobile Applications: Executive Warrior Coach 2.0 (iOS and Android)
JURISDICTIONAL SCOPE
Executive Warrior Academy operates from Australia and provides health coaching services to clients in Australia, the United Kingdom, and the United States.
This Privacy Policy is governed by and complies with:
FOR AUSTRALIAN RESIDENTS:
- Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs)
- Enforced by: Office of the Australian Information Commissioner (OAIC)
FOR UNITED KINGDOM RESIDENTS:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Privacy and Electronic Communications Regulations (PECR)
- Enforced by: Information Commissioner's Office (ICO)
FOR UNITED STATES RESIDENTS:
- Applicable state privacy laws including but not limited to:
- California Consumer Privacy Act (CCPA/CPRA)
- Washington My Health My Data Act (MHMDA)
- [Other applicable state laws based on customer locations]
IMPORTANT NOTICE:
Executive Warrior Academy is NOT a HIPAA covered entity under United States law.
Your health information is protected under Australian, UK, and US state privacy
laws as applicable, but NOT under US federal HIPAA regulations.
COLLECTION NOTICE (Australian Privacy Principles)
Spiritual Family Trust trading as Executive Warrior Academy (ABN: 22 860 118 393)
is bound by the Australian Privacy Principles under the Privacy Act 1988 (Cth).
As a health service provider, we collect and hold health information which is
classified as "sensitive information" under Australian privacy law and is subject
to enhanced protections.
You may deal with us anonymously or by using a pseudonym where it is lawful and
practicable to do so. However, for the provision of health coaching services,
we generally need to identify you to provide effective and safe services.
WHAT INFORMATION WE COLLECT
Personal Information:
- Name, phone number, postal address
- Date of birth, gender
- Payment and billing information
- Account credentials
- Device information (IP address, browser type, operating system)
Use of Cookies
When accessing the Executive Warrior Academy website and apps, Executive Warrior Academy will learn certain information about you during your visit. Similar to other commercial websites, our website utilizes a standard technology called 'cookies' and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.
Use of External Links
Executive Warrior Academy may contain links to many other websites. Executive Warrior Academy cannot guarantee the accuracy of information found at any linked site. Links to or from external sites not owned or controlled by Executive Warrior Academy do not constitute an endorsement by Executive Warrior Academy or any of its employees of the sponsors of these sites or the products or information presented therein.
By accessing this web site, you are agreeing to be bound by these web site Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this web site are protected by applicable copyright and trade mark law.
IP Addresses
IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as “traffic data” so that data (such as the Web pages you request) can be sent to you.
Email Information
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site.
Email Policies
We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and we will not provide your personal information to any third party individual, government agency, or company at any time unless strictly compelled to do so by law.
We will use your e-mail address solely to provide timely information about Executive Warrior Academy.
We will maintain the information you send via e-mail in accordance with applicable federal law.
CAN-SPAM Compliance
In compliance with the CAN-SPAM Act, all e-mail sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.
Choice/Opt-Out
Our site provides users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at anytime.
Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.
Health Information (For provision of health coaching services or initial consult):
- Physical health status and conditions
- Mental health and wellbeing information
- Biohacking protocols and results
- Fitness and activity data
- Nutritional information
- Energy and performance metrics
- Biometric data [if collected]
- Health goals and objectives
- Consultation notes and assessments
Mobile App Data:
- Device identifiers
- Location data [if collected]
- App usage analytics
- Health sensor data [if applicable]
- Photos/camera access [if applicable]
Intellectual Property Rights
All copyrights, trademarks, patents and other intellectual property rights in and on our website and mobile applications, and all content and software located on the site and mobile applications, shall remain the sole property of Executive Warrior Academy or its licensors. The use of our trademarks, content and intellectual property is forbidden without the express written consent from Executive Warrior Academy.
You must not:
Republish material from our website and mobile applications without prior written consent.
Sell or rent material from our website.
Reproduce, duplicate, create derivative, copy or otherwise exploit material on our website for any purpose.
Redistribute any content from our website, including onto another website.
Acceptable Use
You agree to use our website and mobile applications only for lawful purposes, and in a way that does not infringe the rights of, restrict or inhibit anyone else’s use and enjoyment of the website and mobile applications. Prohibited behavior includes harassing or causing distress or inconvenience to any other user, transmitting obscene or offensive content or disrupting the normal flow of dialogue within our website and mobile applications.
You must not use our website and mobile applications to send unsolicited commercial communications. You must not use the content on our website and mobile applications for any marketing related purpose without our express written consent.
Restricted Access
We may in the future need to restrict access to parts (or all) of Executive Warrior Academy website and mobile applications, and reserve full rights to do so. If, at any point, we provide you with a username and password for you to access restricted areas of our website and mobile applications, you must ensure that both your username and password are kept confidential.
Use of Testimonials
In accordance with with the FTC guidelines concerning the use of endorsements and testimonials in advertising, please be aware of the following:
Testimonials that appear on this site are actually received via text, audio or video submission. They are individual experiences, reflecting real life experiences of those who have used our products and/or services in some way. They are individual results and results do vary. We do not claim that they are typical results. The testimonials are not necessarily representative of all of those who will use our products and/or services.
The testimonials displayed in any form on this site (text, audio, video or other) are reproduced verbatim, except for correction of grammatical or typing errors. Some may have been shortened. In other words, not the whole message received by the testimonial writer is displayed when it seems too lengthy or not the whole statement seems relevant for the general public.
Executive Warrior Academy is not responsible for any of the opinions or comments posted on Executive Warrior Academy website and mobile applications. Executive Warrior Academy is not a forum for testimonials, however provides testimonials as a means for customers to share their experiences with one another. To protect against abuse, all testimonials appear after they have been reviewed by management of Executive Warrior Academy. Executive Warrior Academy doe not share the opinions, views or commentary of any testimonials on Executive Warrior Academy website and mobile applications – the opinions are strictly the views of the testimonial source.
The testimonials are never intended to make claims that our products and/or services can be used to diagnose, treat, cure, mitigate or prevent any disease. Any such claims, implicit or explicit, in any shape or form, have not been clinically tested or evaluated.
WHY WE COLLECT YOUR INFORMATION
Broadly speaking, we use personal information for purposes of administering our business activities, providing customer service and making available other items and services to our customers and prospective customers.
Executive Warrior Academy will not obtain personally-identifying information about you when you visit our site, unless you choose to provide such information to us, nor will such information be sold or otherwise transferred to unaffiliated third parties without the approval of the user at the time of collection.
We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights.
Primary Information Collection Purposes:
- To provide executive health coaching services
- To develop personalized biohacking and wellness protocols
- To monitor your progress and adjust recommendations
- To communicate with you about your programs
- To process payments and maintain accounts
- To comply with legal and regulatory obligations
Secondary Purposes (Related to Primary Purpose):
- To improve our services and develop new offerings
- For quality assurance and training purposes
- To send you relevant health and wellness content [with consent]
- For data analytics to enhance service delivery
WHO WE SHARE YOUR INFORMATION WITH
We may store your personal and health information in:
- Cloud service providers [specify: AWS, Google Cloud, etc.]
- Payment processors [specify: Stripe, PayPal, etc.]
- Email service providers [specify: e.g., Mailchimp, ConvertKit]
- Analytics providers [specify: Google Analytics, etc.]
- Professional advisors (lawyers, accountants) when necessary
- Law enforcement or regulatory bodies when legally required
OVERSEAS DISCLOSURE
Your information may be disclosed to recipients located in:
- United States (cloud hosting, service providers)
- United Kingdom (if applicable)
- [Other countries where your service providers are located]
We take reasonable steps to ensure overseas recipients comply with the Australian Privacy Principles or you will be provided with notice and consent options.
CONSEQUENCES OF NOT PROVIDING INFORMATION
If you choose not to provide certain personal or health information, we may not be able to:
- Provide you with health coaching services
- Personalise your wellness protocols
- Communicate effectively with you
- Process payments or maintain your account
HOW WE USE YOUR WEBSITE AND MOBILE APP DATA?
Executive Warrior Academy may use software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different sections of our site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.
For site security purposes and to ensure that this service remains available to all users, Executive Warrior Academy uses software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.
HOW WE USE YOUR HEALTH INFORMATION COLLECTED DURING PRIVATE HEALTH COACHING OR INITIAL CONSULTATION?
We will only use or disclose your personal and health information:
- For the primary purpose for which it was collected
- For a secondary purpose that is directly related to the primary purpose and
you would reasonably expect us to use it
- With your consent
- Where required or authorised by law
- To lessen or prevent a serious threat to life, health, or safety
We will NOT use your health information for direct marketing purposes without your consent.
INTERNATIONAL DATA TRANSFERS
Operating from Australia with clients in the UK and USA requires us to transfer your data internationally.
Australian Residents:
Before we disclose your personal information to overseas recipients, we will:
- Take reasonable steps to ensure the recipient does not breach the Australian
Privacy Principles, OR
- Obtain your consent to the disclosure after informing you that APP 8.1 will
not apply to the disclosure
UK Residents:
We ensure appropriate safeguards are in place for transfers of your data outside
the UK in accordance with UK GDPR requirements, including:
- Standard Contractual Clauses with service providers
- Adequacy decisions where applicable
- Your explicit consent where required
US Residents:
We comply with applicable state data protection laws regarding cross-border transfers and data localization requirements.
SECURITY OF YOUR INFORMATION
We take reasonable steps to protect your personal and health information from:
- Misuse, interference, and loss
- Unauthorised access, modification, or disclosure
Security measures include:
- Encryption of data in transit (TLS/SSL)
- Encryption of data at rest
- Multi-factor authentication for administrative access
- Regular security audits and vulnerability assessments
- Access controls limiting staff access to necessary information only
- Secure backup procedures
- Staff training on privacy and security obligations
- Vendor security assessments
Mobile App Security:
- Secure authentication protocols
- Local data encryption on devices
- Secure API communications
- Regular security updates
YOUR RIGHTS TO ACCESS AND CORRECT YOUR INFORMATION
You have the right to:
- Request access to the personal and health information we hold about you
- Request correction of inaccurate, out-of-date, incomplete, or misleading
information
How to Request Access or Correction:
Use this Form Private Data Removal/Amendment Form - Executive Warrior Academy
We will respond to your request within 30 days. There is no fee for making a
request, though we may charge a reasonable fee for providing access in some
circumstances.
We may refuse access in limited circumstances permitted under the Privacy Act,
such as where:
- Giving access would pose a serious threat to life, health, or safety
- Giving access would have an unreasonable impact on another person's privacy
- The request is frivolous or vexatious
- Legal proceedings are underway
If we refuse access or correction, we will provide you with written reasons and
information about how to complain.
DATA BREACH NOTIFICATION
Under the Notifiable Data Breaches (NDB) scheme in the Privacy Act, we are required to notify you and the Office of the Australian Information Commissioner (OAIC) if we experience a data breach that is likely to result in serious harm.
If a notifiable data breach occurs, we will:
- Assess the breach and determine if it is likely to result in serious harm
- Take steps to remediate the breach
- Notify affected individuals as soon as practicable
- Notify the OAIC
- Provide recommendations on steps you can take to reduce the risk of harm
You can report suspected data breaches to: Support - Executive Warrior Academy
HOW TO MAKE A COMPLAINT
If you believe we have breached your privacy rights under the Privacy Act, you have the right to make a complaint.
Internal Complaint Process:
1. Contact our Privacy Officer: Support - Executive Warrior Academy
2. We will:
• Acknowledge your complaint within 14 days
• Investigate the matter
• Respond within 30 days with our decision and reasons
External Complaint:
If you are not satisfied with our response, you can lodge a complaint with:
Office of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Website: www.oaic.gov.au
Post: GPO Box 5218, Sydney NSW 2001
UK Residents:
Information Commissioner's Office (ICO)
Website: www.ico.org.uk
Phone: 0303 123 1113
US Residents:
Contact the relevant state attorney general or consumer protection office.
IMPORTANT DISCLAIMERS
NOT A HIPAA COVERED ENTITY:
Executive Warrior Academy is not a healthcare provider, health plan, or healthcare clearinghouse as defined under the US Health Insurance Portability and Accountability Act (HIPAA). We are not a HIPAA covered entity or business associate. Your health information is protected under Australian Privacy Act, UK GDPR, and applicable US state privacy laws, but NOT under HIPAA.
NOT MEDICAL ADVICE:
Our health coaching services, including biohacking and functional medicine protocols, are for wellness and performance optimization purposes. This is not medical advice, diagnosis, or treatment. Always consult with qualified healthcare professionals for medical concerns.
Executive Warrior Academy makes no representations, warranties, or assurances as to the accuracy, currency or completeness of the content contain on this website or any sites linked to this site, and mobile applications.
All the materials on this site are provided ‘as is’ without any express or implied warranty of any kind, including warranties of merchantability, noninfringement of intellectual property or fitness for any particular purpose. In no event shall Executive Warrior Academy or its agents or associates be liable for any damages whatsoever (including, without limitation, damages for loss of profits, business interruption, loss of information, injury or death) arising out of the use of or inability to use the materials, even if Executive Warrior Academy has been advised of the possibility of such loss or damages.
CHANGES TO THIS POLICY:
We may update this Privacy Policy from time to time. We will notify you of material changes by:
- Posting the updated policy on our website and in our mobile app
- Updating the "Last Updated" date
- Sending you email notification for significant changes [if applicable]
Your continued use of our services after changes constitutes acceptance of the updated Privacy Policy.