1. About this policy

1.1 This Privacy Policy explains how Emily de Kort trading as Family Centred Sleep ABN 90 529 473 237, of Albury NSW 2640 (we, us, our), collects, uses, stores and shares personal information. It applies to everyone who uses our website, services, programs, memberships, community spaces and social media channels.

1.2 We provide sleep support for babies and toddlers, and we hold health information about the children we support. This means we are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We also comply with the Health Records and Information Privacy Act 2002 (NSW) where it applies to us, and, for families in the United Kingdom, the UK General Data Protection Regulation (UK GDPR).

1.3 This policy should be read with our Terms and Conditions. Where this policy and the Terms both deal with privacy, this policy applies.

1.4 Personal information means information or an opinion about an identified person, or a person who can reasonably be identified, whether or not it is true.

1.5 Health information is a type of sensitive information. It includes information about a person's health, development, feeding, sleep, medical conditions, medication and the services provided to them. Information about your child's sleep and wellbeing is health information, and we handle it with extra care.

2. What we collect and how

2.1 Depending on how you use our services, we may collect:

• About you: your name, email address, phone number, postal address, time zone, and the names of other parents or carers taking part in support.
• About your child: their name, date of birth, sleep patterns, feeding, routines, development, medical conditions, medication, sleep environment, and any advice from their health professionals.
• During support: your intake form, sleep logs, messages, call notes, plans, roadmaps and, only if you agree, call recordings.
• Purchases and payments: what you bought, when, and payment status. Card details are handled by our payment providers and we do not store them.
• Community and programs: posts, comments and messages you share in our membership, group program and community spaces.
• Marketing and enquiries: details you give when you join our email or SMS list, download a freebie, attend a webinar, send us a direct message, or enquire about our services.
• Website and social media: how you use our website and respond to our emails and ads (see section 7).

2.2 How we collect it. We collect most information directly from you, through our forms, booking tools, calls, messages, sleep logs and community spaces. Information about your child comes from you as their parent or carer. With your consent, we may also receive information from a health professional who refers you to us.

2.3 Information about other people. If you give us information about another person, such as your partner or your child, please make sure they know you are sharing it with us and where to find this policy.

2.4 Unsolicited information. If we receive personal information we did not ask for and do not need, we will destroy or de-identify it where it is lawful and reasonable to do so.

2.5 Using a pseudonym. You can ask general questions or follow us on social media without giving your name. To provide personalised support, we need your real details.

2.6 If you do not give us information. If you choose not to give us the information we ask for, we may not be able to provide our services, or provide them safely.

3. How we use your information

3.1 We use personal information to:

• provide, personalise and deliver our services, including your plan, sleep log reviews, calls and roadmap;
• keep your child safe, including identifying when to suggest medical advice;
• book calls, send reminders, and communicate with you about your service;
• process payments and manage your account, membership or program place;
• respond to enquiries, feedback and complaints, and manage claims under our Never Left Guessing Guarantee;
• run our community spaces and keep them safe and respectful;
• improve our services, including through anonymous, de-identified analysis;
• send you marketing, where you have agreed to receive it; and
• meet our legal, insurance and record-keeping obligations.

3.2 Consent to health information. We only collect health information about you or your child with your consent and where it is reasonably necessary to support you. By completing our intake form, you consent to us collecting and using it for the purposes in clause 3.1. You can withdraw consent at any time, but we may then be unable to continue supporting you safely.

3.3 Other uses. We will only use or share your information for another purpose if you would reasonably expect it and it is related to the original purpose (directly related for health information), if you consent, or if the law requires or allows it, for example to lessen a serious threat to someone's life, health or safety.

3.4 Marketing. We only send marketing emails or texts where you have opted in, or where the law otherwise allows. Every marketing message tells you how to unsubscribe, such as using the link in an email or replying STOP to a text, and we act on your request promptly. We never use your child's health information for marketing. Service messages about support you have bought are not marketing and are still sent while your service is active.

3.5 Case studies and testimonials. We only use your story, feedback, photos or results in case studies, testimonials or marketing with your separate permission, given by ticking the optional box in your intake form or by saying yes when we ask. We remove names and identifying details unless you agree otherwise. You can withdraw your permission at any time, and we will stop any new use.

3.6 Software and AI tools. We use software tools, which may include AI-assisted tools, to help us organise information and draft materials to support sleep. Every plan and piece of advice is reviewed and approved by our human consultant before it reaches you. Sleep is human.

3.7 Automated decisions. We do not use computer programs to make decisions that could significantly affect your rights or interests. Decisions about your support are made by a person.

4. Who we share it with

4.1 We never sell or rent your personal information. We only share it with people and providers who help us deliver our services, and only what they need.

4.2 Our team. Our consultants and business partner, who are bound by confidentiality.

4.3 Service providers. We use the following types of providers:

Purpose	Examples of providers we use	Where data may be stored
Website, forms, bookings, email and SMS	FG Funnels	Australia and the United States
Membership and community spaces	Circle	United States
Video calls	Zoom	United States and other countries
Messaging	WhatsApp (Meta)	United States and other countries
Email, calendar and file storage	Google Workspace	United States and other countries
Payments	Our payment processors	Australia, the United States and other countries
Website analytics and advertising	Google Analytics, Meta	United States and other countries

We may also share information with our professional advisers, insurers and IT support where needed.

4.4 Overseas disclosure. Because many of these providers are based overseas, your information, including health information, may be stored or accessed outside Australia, mainly in the United States. We choose reputable providers with strong security and take reasonable steps to make sure they handle your information in line with the APPs. Where a provider is overseas, Australian privacy law may not fully apply to them.

4.5 Health professionals. We will only share information with your child's doctor or another health professional with your consent, or where the law allows, such as a serious threat to someone's health or safety.

4.6 When the law requires it. We may disclose information where required or authorised by law, such as to a court, regulator or child protection authority.

4.7 If our business changes hands. If all or part of our business is sold or restructured, personal information may be transferred to the new owner, who must continue to protect it in line with this policy.

5. Storage, security and retention

5.1 How we store it. We store information electronically in secure, password-protected systems run by us or our service providers. We do not keep paper client files. If we take handwritten notes, we store them securely and destroy them once they are recorded electronically.

5.2 How we protect it. We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, change or disclosure. These include strong passwords and two-factor authentication on our accounts, limiting access to people who need it, keeping devices secure and up to date, and choosing providers with recognised security standards.

5.3 How long we keep it. We keep client records, including health information, for 7 years after your support ends. If the information was collected while your child was under 18, we keep it until your child turns 25, where the law requires. We keep marketing details until you unsubscribe or ask us to delete them. After that, we securely destroy or de-identify the information, unless we must keep it for a legal reason.

5.4 Data breaches. If a data breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme, and tell you what steps you can take to protect yourself.

6. Your rights

6.1 Access and correction. You can ask to see the personal information we hold about you or your child, and ask us to correct anything that is wrong, out of date or incomplete. Email us using the details in section 8. We will respond within 30 days. There is no charge to make a request. In rare cases we may charge a reasonable fee for providing a large volume of material, and we will tell you before any cost is incurred.

6.2 If we say no. In limited cases the law allows us to refuse access, for example where it would unreasonably affect someone else's privacy or pose a serious threat to someone's safety. If we refuse, we will tell you why in writing and how to complain.

6.3 Deletion. You can ask us to delete your information. We will do so unless we need to keep it to meet our legal or record-keeping obligations under clause 5.3, and we will tell you if that is the case.

6.4 United Kingdom and European families. If you live in the UK or the European Economic Area, UK GDPR or EU GDPR may give you additional rights, including to have your information erased, to restrict or object to how we use it, to receive it in a portable format, and to withdraw consent at any time. We use your information because we need it to provide the services you bought, with your explicit consent for health information, and where we have a legitimate interest such as improving our services. You can complain to the Information Commissioner's Office (ico.org.uk).

6.5 Families elsewhere. If you live in another country, including the United States, you may have rights under your local privacy laws. Contact us and we will respond in line with the law that applies to you.

7. Website, cookies and advertising

7.1 Cookies. Our website uses cookies, which are small files stored on your device. Some are needed for the site to work. Others help us understand how visitors use the site and measure our advertising.

7.2 Analytics. We use tools such as Google Analytics to collect information like the pages you visit, how you found our site, your general location, device and browser type, and IP address. We use this in a combined form to improve our website and content.

7.3 Advertising. We use advertising tools such as the Meta Pixel and Google advertising tags. These help us show our ads to people who may find them useful, including people who have visited our website, and measure how well our ads work. These tools do not receive your child's health information, your intake form or your sleep logs.

7.4 Your choices. You can block or delete cookies in your browser settings, though some parts of the site may not work properly. You can adjust the ads you see through your Meta and Google ad settings, and opt out of Google Analytics using Google's opt-out browser add-on.

7.5 Social media. When you interact with us on Instagram, Facebook or other platforms, the platform's own privacy policy also applies. Please do not share your child's health details in public comments. Send us a direct message or email instead.

8. Complaints, changes and contact

8.1 Complaints. If you are concerned about how we have handled your personal information, please email our Privacy Officer using the details below. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days, letting you know the outcome in writing.

8.2 If you are not satisfied. You can contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992. For health information handled in NSW, you can also contact the NSW Information and Privacy Commission at www.ipc.nsw.gov.au. UK families can contact the Information Commissioner's Office at ico.org.uk.

8.3 Changes to this policy. We review this policy regularly and will publish any changes on our website with a new date. If a change significantly affects how we use information you have already given us, we will tell you by email first.

8.4 Contact us. Privacy Officer: Emily de Kort Family Centred Sleep ABN 90 529 473 237 Albury NSW 2640 Email: emily@familycentredsleep.com

You can request a free copy of this policy in another format by emailing us.

Last updated: 25 October 2026