We respect your privacy.
Coaching by Niti Pty Ltd (as Trustee for the NN & RN Family Trust ABN 68 567 948 414) (“Coaching by Niti”, “we”, “us”, “our”) respects, and is committed to safeguarding, your privacy. We believe that information received by us that can be used to identify an individual user (“you”, “your”, “User”) should be taken very seriously. We are committed to the security and confidentiality of your personal information, and are transparent in how we manage it. Unless given consent to do otherwise, we will only collect and use personal information as set out below.

We follow the spirit of the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the “Privacy Act”). However, until such time (if at all) as we are subject, in whole or in part, to the Privacy Act, we have chosen not to opt in to be treated as an organisation for the purposes of the Act.

This Privacy Policy sets out our commitment to protecting the privacy of your personal information that we collect through our website and/or services. Our website and/or services includes any websites, applications or platforms operated by us or associated business names registered by us.

By providing us with personal information, you indicate that you have had sufficient opportunity to access this Privacy Policy and that you have read and accepted it. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If you do not wish to provide personal information to us, then you do not have to do so, however it may affect your use of our website and/or services. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We may update this Privacy Policy from time to time. We encourage you to review this Privacy Policy periodically to stay informed about our collection, use and disclosure of personal information. Your continued use of our website and/or services or any other content, products or services covered by this Privacy Policy constitutes your agreement to this Privacy Policy and any updates.

By using our website and/or services and providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your account information and usage.

We keep our privacy policy under regular review.It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1. Important information and who we are

A. Purpose of this Privacy Policy

This privacy policy aims to give you information on how Coaching by Niti collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to an email list, sign up for any other free information on the website, submit a question or comment to Coaching by Niti via the website or purchase a product or service on the website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

B. Changes to the Privacy Policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

C. Third-party Links

This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data we collect about you

Personal Information as used in this policy, is personally identifiable information, such as your first and last name, mailing address, email address, billing information, IP addresses, demographics, telephone numbers and/or other online contact information. Personal Information can also include data that is usually non-personally identifiable data (such as location data, data about personal attributes or online identifiers) but that, taken together with other collected data, identifies a natural person, either directly or indirectly.

We collect personal information, as well as non-personally identifiable information on our website and/or services. We try to only collect personal information about you that we need for the operation of our website and/or services, and to market and promote our website and/or services. The kinds of personal information we collect and hold about you may depend on the circumstances in which the information is collected.

Sensitive Information includes information about a person’s racial or ethnic origin, religious beliefs or affiliations, political opinions, philosophical beliefs, health or genetic information, sexual preference or information about whether an individual is a member of a professional or trade association or union. Sensitive information might be collected by us during the course of surveys administered by Coaching by Niti or affiliated third parties, but only if volunteered by Users with their consent.

You can choose not to actively volunteer information to Coaching by Niti. However, if you do provide information to us when asked or prompted, including sensitive information you are also providing consent for Coaching by Niti to collect, store and use that information as necessary for the purpose of collecting it. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy).

If your personal information is collected by us from a third party, we are under no obligation to inform you of the collection, but such information will be subject to this policy and will be accessible by you on request, subject to any limitations or exceptions in the law.

3. How is your personal data collected

We will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy or if it is otherwise lawful to do so. The only personal information collected by us is what has been collected by or provided to us in accordance with this Privacy Policy or which has been provided to us lawfully by third parties, including our clients, customers and service providers.

We use different methods to collect information about you including through:

A. Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes, but is not limited to, personal data you provide when you:

i. register interest in and/or purchase our products or services;
ii. provide your name, email address or other information to us voluntarily, whether by email, post, social media, phone call or otherwise;
iii. subscribe to our publications;
iv. send us an inquiry;
v. book an introductory or chemistry call; or
vi. complete feedback requests or surveys.

B. Automated technologies or interactions

[As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.]

C. Third parties or publicly available sources

We may receive personal data about you from legitimate third party sources including social media, our website, list brokers, referral agents and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so.

We may use analytics tools and other third party technologies (for example, Google Analytics) to collect non-personally identifiable information in the form of various usage and user metrics when you use our website and/or Services. These third party analytics companies may combine the information they have independently collected across their network of websites, products and services.

We may monitor and record calls and other electronic communications that you make to us in certain circumstances. For example, calls to us may be monitored and recorded for training and customer service purposes.

We use social networking services such as Twitter, Facebook, Instagram, TikTok and LinkedIn to communicate with the public about us. When you communicate with us using these services we may collect your personal information. The social networking service will also handle your personal information for its own purposes. These sites have their own privacy policies.

4. How we use your personal data

We will only use your personal data where we are permitted to do so by applicable law. We collect and use personal information for purposes including to contact and communicate with you, for internal record keeping, marketing and for our email blogs and other activities associated with our business. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

A. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client

(a) Identity
(b) Contact Performance of a contract with you

To enable you to submit an enquiry to us, whether through email, our website, or via social media

(a) Identity
(b) Contact

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to enable us to respond to your enquiry)

To enable you to book a call with us through Calendly or by email

(a) Identity
(b) Contact

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to enable us to send you a calendar invitation and speak with you about your needs)

To process and deliver our services to you including:

(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to register for an email list / email marketing

(a) Identity
(b) Contact
(c) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide you with the newsletter/email marketing and present you with information, goods or services we consider you may be interested in)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical
(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

B. Marketing

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you haven’t opted out of receiving that marketing. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your express consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this won’t apply to personal data provided to us as a result of a product/service purchase, or other transactions.

C. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.

D. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with external third parties for the purposes set out in the table Purposes for which we will use your personal data above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

We may disclose your personal information to our employees, insurers, professional advisors, agents, financiers, suppliers or subcontractors and other users as permitted by the functionality of our website and Services insofar as reasonably necessary for the purposes set out in this policy.

We may also contract with third parties to supply services to you on our behalf, including credit card processing services, order fulfilment service providers, analytics service providers, email/campaign management service providers, website management service providers, information technology and related infrastructure providers and email deliver service providers. The third party processors we use include Calendly (a scheduling service for booking appointments), Paypal (for processing online payments), Xero (for processing invoice payments) and Medoo (a platform for providing coaching interactions). Each of these entities is bound by their own data processing obligations.

We may from time to time need to disclose personal information to comply with a legal requirement, in the course of a legal proceeding or in response to a law enforcement agency request. We may also use your personal information to protect our copyright, trademarks, legal rights, property or safety of us, our customers or third parties.

6. Data retention & security

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We take measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all personal information that we collect. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps.

We are committed to ensuring that the information you provide is secure. We use reasonable technical, administrative and physical measures to safeguard personal information. However, no personal information shared on the internet can be 100% guaranteed to be secure. Users are responsible for the access and security of their own computers.

7. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

A. If you want us to establish the data’s accuracy.
B. Where our use of the data is unlawful but you do not want us to erase it.
C. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
D. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.

A. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

B. What we may need for you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

C. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. When your information leaves Australia

Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia. We will only transfer personal information to a foreign country for the purpose of providing you with our services and for carrying out any request you make when you use and interact with our website and services (e.g., if we outsource data storage to a cloud service provider).

In the event that we are required to disclose your personal information to overseas third parties, we will take reasonable steps to ensure that such disclosures are subject to reasonable confidentiality terms.

9. Privacy data breaches
Australian laws provide that an eligible data breach arises when the following three criteria are satisfied:
A. there is unauthorised access to or unauthorised disclosure of personal information, or a loss of personal information, that we hold;
B. this is likely to result in serious harm to one or more individuals; and
C. we have not been able to prevent the likely risk of serious harm with remedial action.

We are required to take all reasonable steps to ensure an assessment of an eligible data breach is completed within 30 days. If an eligible data breach is confirmed, as soon as practicable we must provide a statement to each of the individuals whose data was breached or who are at risk, including details of the breach and recommendations of the steps individuals should take. A copy of the statement must also be provided to the Office of the Australian Information Commissioner.

10. How to contact us about your privacy

If you want to send us notices or service of process, please contact us at


Coaching by Niti Pty Ltd c/o Smarter Numbers, 1226 Main Road, Eltham VIC 3095

Privacy Complaints

If you have a complaint, please email us at We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

If you have any complaints about our privacy practices, please feel free to send details of your complaint to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001 Phone 1300 363 992 or