PRIVACY POLICY

ABN: 36 168 501 808 | Effective Date: 1 January 2025 | Last Updated: March 2025

Quality Mind AI Pty Ltd (‘Quality Mind AI’, ‘we’, ‘us’, or ‘our’) is committed to protecting the privacy and confidentiality of your personal information. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

By using our website, platform, applications, or services, you consent to the practices described in this policy. If you do not agree, please discontinue use of our services and contact us to request deletion of your data.

1. ABOUT QUALITY MIND AI

Quality Mind AI is an AI – powered mental wellness and performance coaching platform built on the proprietary Neuro – Repetition™ methodology. We serve businesses, and coaches/practitioners across Australia, with a focus on employee wellbeing, psychosocial safety, and behavioural resilience.

Registered Address: 115 Ormond Road, Elwood, Victoria 3184, Australia
Website: www.qualitymind.ai
Contact Email:support@qualitymindglobal.com

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that is reasonably necessary to provide our services. This may include:

Identity & Contact Information:

  • Full name, email address, phone number, and postal address
  • Job title, organisation name, and industry sector

Account & Platform Information:

  • Login credentials and account preferences
  • Coaching session records, progress data, and platform usage history
  • Responses to assessments, questionnaires, and wellbeing check-ins

Health & Sensitive Information:
Where relevant to the delivery of mental wellness or coaching services, we may collect sensitive information including psychological wellbeing data, stress and mental health indicators, and self – reported health information. We will always seek your explicit consent before collecting sensitive information, in accordance with APP 3.

Technical & Usage Data:

  • IP address, browser type, device identifiers, and operating system
  • Pages visited, session duration, and interaction patterns on our platform
  • Cookies and similar tracking technologies (see Section 8)

3. HOW WE COLLECT INFORMATION

We collect information in the following ways:

  • Directly from you when you register, purchase, or engage with our platform or services
  • From your organisation where we are engaged as a business partner or employee wellbeing provider
  • Automatically via platform analytics and session tracking tools
  • From third – party integrations where you have authorised a connection (e.g., HR systems)
  • Through surveys, assessments, and coaching interactions on our platform

4. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

  • To deliver, personalise, and improve our coaching and AI platform services
  • To provide support, respond to enquiries, and communicate about your account
  • To process transactions and manage billing
  • To generate anonymised, aggregated organisational wellbeing insights for business clients
  • To conduct research and development to improve our Neuro – Repetition™ methodology and AI models
  • To meet our legal, compliance, and regulatory obligations, including Australia’s Work Health and Safety (WHS) psychosocial safety frameworks
  • To send relevant service updates, product communications, and (where consented) marketing materials

We will not use your personal information for any secondary purpose without your consent, unless permitted by the Privacy Act 1988 (Cth).

5. AI PROCESSING & DATA USE

Quality Mind AI uses artificial intelligence to power personalised coaching experiences. We are committed to responsible, transparent AI use:

  • Your data may be used to train, refine, or evaluate our AI models in an anonymised or de-identified form only
  • Personally identifiable information is never used to train external third – party AI models without your explicit consent
  • AI – generated coaching outputs are supplementary and do not replace professional mental health or medical advice
  • You have the right to request a human review of any AI – generated decision that significantly affects you

We apply appropriate safeguards to ensure that AI processing of sensitive wellbeing data meets reasonable standards of accuracy, fairness, and privacy.

6. DISCLOSURE OF PERSONAL INFORMATION

We do not sell your personal information. We may disclose information to:

  • Our employees, contractors, and service providers who assist in delivering our platform and services, under strict confidentiality obligations
  • Your employing organisation, where we are engaged to provide workplace wellbeing services — limited to aggregated, de -identified data unless you have separately consented to individual reportingt
  • Government and regulatory authorities where required by law
  • Third – party technology providers (e.g., cloud hosting, payment processing, analytics) under data processing agreements that comply with the APPs

Where we disclose information to overseas recipients, we will take reasonable steps to ensure the recipient handles your information in accordance with the Australian Privacy Principles, or we will seek your consent

7. DATA STORAGE & SECURITY

We take reasonable steps to protect your personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. Our measures include:

  • Encrypted data transmission via SSL/TLS technology
  • Secure cloud infrastructure with role -based access controls
  • Regular security assessments and vulnerability scanning
  • Staff training on privacy and data handling obligations

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the
Privacy Act 1988 (Cth).

Notification will occur as soon as practicable, and no later than 30 days after we become aware of the eligible data breach.

8. COOKIES & TRACKING TECHNOLOGIES

We use cookies and similar technologies to improve your experience on our platform. These may include:

  • Essential cookies required for platform functionality and security
  • Analytics cookies to understand how our platform is used (e.g., session duration, page views)
  • Preference cookies to remember your settings and customisations

We do not use cookies for third – party advertising or behavioural tracking. You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect platform functionality.

We honour Do Not Track (DNT) browser signals and do not engage in cross- site behavioural tracking.

9. YOUR PRIVACY RIGHTS

Under the Australian Privacy Principles, you have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate, outdated, or incomplete information
  • Request deletion of your personal information, subject to legal retention requirements
  • Withdraw consent to the collection or use of your information at any time
  • Opt out of marketing communications at any time via the unsubscribe link in our emails, or by contacting us directly
  • Lodge a complaint with us, or with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au

To exercise any of these rights, please contact us at support@qualitymindglobal.com. We will respond to requests within 30 days. In some cases, we may need to verify your identity before processing a request.

When a deletion request is received, your data will be removed from active systems within 48 hours and from backup systems within 30 days. Confirmation will be sent via email.

10. DATA RETENTION

We retain personal information only for as long as necessary to fulfil the purpose for which it was collected, or as required by law. Retention periods are:

  • Active account data: retained for the duration of your account plus 7 years (in line with Australian financial record – keeping obligations)
  • Coaching and session records: retained for 7 years from last interaction
  • De – identified analytical data: may be retained indefinitely for research and improvement purposes

Where information is no longer required, we will securely destroy or de – identify it.

11. CHILDREN'S PRIVACY

Our platform and services are not directed at children under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately at support@qualitymindglobal.com and we will promptly delete it.

12. MARKETING COMMUNICATIONS

We may send you information about our services, updates, and relevant industry insights where you have consented or where we have a legitimate interest in doing so. All marketing emails will:

  • Clearly identify Quality Mind AI as the sender
  • Include a clear and functional unsubscribe mechanism
  • Include our registered business address

To unsubscribe at any time, use the link in the email footer or contact us at support@qualitymindglobal.com.

13. THIRD - PARTY LINKS & INTEGRATIONS

Our website and platform may contain links to third – party websites or integrate with third – party tools (e.g., HR platforms, calendar systems). We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you access via our platform.

14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our services, legal obligations, or business practices. Material changes will be notified via:

Your continued use of our services after the effective date of any changes constitutes acceptance of the updated policy. The current version and effective date are always displayed at the top of this document.

15. COMPLAINTS & CONTACT

If you have a concern or complaint about how we have handled your personal information, we encourage you to contact us first so we can resolve the matter directly.

Email:support@qualitymindglobal.com
Website: www.qualitymind.ai

Address: Quality Mind AI, 115 Ormond Road, Elwood, Victoria 3184, Australia

We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.

If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC):

Human Intelligence. Reinforced by AI. Delivered at Scale.

Quality Mind AI Pty Ltd | ABN: 36 168 501 808 | www.qualitymind.ai