Privacy Policy

1. Who this policy covers

Sowilo Society ("we", "us", "our") is owned and operated by Lisa Gaukroger, ABN 76454374721, based in NSW, Australia.

This policy applies to everyone who interacts with us, including:

- Visitors to [yourwebsite.com]

- coaching clients

- Spinal Energetics clients

- Event, challenge, or workshop participants

- Email subscribers and newsletter members

- Anyone who purchases a product, program, or service from us

Because we work with clients globally, this policy is written to align with:

- The Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) — which apply to us regardless of business size, because we provide services involving health information

- The General Data Protection Regulation (GDPR) for clients in the EU/UK

- General international best practice for clients elsewhere (including the US)

2. The personal information we collect

General information, collected when you enquire, book a call, purchase a program, register for an event/challenge, or subscribe:

- Name, email address, phone number, postal address

- Date of birth

- Billing and payment information (processed securely by our payment provider — we do not store full card details ourselves)

- Communications you send us (emails, DMs, form submissions)

- Emergency contact details, dietary requirements, or accessibility needs, if collected for live events

- Account credentials, if you create a login for any client portal

- Website usage data (via cookies/analytics — see Section 8)

Sensitive information (treated with extra care), collected specifically for coaching and Spinal Energetics work:

- Health-related information you choose to share during intake or sessions — e.g. physical conditions, current medications, relevant medical history, nervous system patterns, emotional or psychological context

- Information shared during 1:1 sessions relevant to your coaching or energetic work. [If applicable: birth date, time, and location, where used for Human Design or Astrology-informed coaching]

- We only collect sensitive/health information with your clear, explicit, opt-in consent, separate from general terms of service, and only where it's genuinely needed to provide the service you've asked for. You can decline to share it, though this may limit what we're able to offer you.

3. Our legal basis for processing your information

For clients in the EU/UK, and as good practice more broadly, we rely on the following legal bases:

- Consent — for sensitive/health information, and for marketing emails

- Contract — to deliver the coaching or Spinal Energetics services you've purchased

- Legitimate interests — to operate, secure, and improve our business and website

- Legal obligation — to meet accounting, tax, and record-keeping requirements

4. Why we collect and how we use it

We use your information to:

- Deliver Rewired for Wealth coaching and Spinal Energetics sessions

- Process payments and manage your account

- Register you for and run events, workshops, and challenges

- Communicate with you about bookings, programs, and support

- Send marketing emails and newsletters (only if you've opted in — you can unsubscribe anytime)

- Improve our website, offers, and client experience

- Prevent fraud and keep our systems and services secure

- Meet legal and accounting obligations

- We do not sell your personal information. We do not use your health information for marketing purposes.

5. Who we share it with

We share information only where necessary, with the following categories of third-party service providers.

These providers only receive the information needed to perform their function and are contractually bound to protect it and use it only for the purposes we specify.

- Legal disclosures. We may disclose information where required by law, to protect our legal rights, to investigate potential wrongdoing, or to protect the safety of any person.

- Business transfers. If Sowilo Society is ever involved in a merger, acquisition, or sale of some or all of its assets, your information may be transferred as part of that transaction. We'll notify you of any such change and any choices you may have.

- With your consent. We may share information with other third parties when you've given us explicit permission to do so.

We don't share client information with anyone else without your consent, unless required by law.

6. Sending and receiving information internationally

Several of the tools above (e.g. Stripe, Zoom, Google, Flodesk, Ivorey) store or process data outside Australia, including in the United States. Under Australian Privacy Principle 8, we're required to take reasonable steps to ensure any overseas recipient doesn't breach the APPs in relation to your information. We choose providers with strong security and privacy standards.

If you're accessing our services from outside Australia, your information will also be transferred to and processed in Australia, and possibly other countries where our service providers operate, which may have different data protection laws to your home country. By using our services, you consent to this international handling of your information for the purposes described in this policy.

7. Health information — additional protections

Because Spinal Energetics and parts of the coaching process involve information about your health and nervous system, we apply extra safeguards:

- We collect health-related information only with your specific, informed consent (not bundled into general sign-up terms)

- It's used only for the purpose of delivering your sessions and supporting your work with us

- It's stored securely and access is limited to [you / you and any practitioners you work with]

- It's never shared with third parties except as required by law or with your explicit permission

You can ask to see, correct, or request deletion of this information at any time (see Section 11)

Retention periods are set out in Section 10 below

Health & wellness disclaimer: Spinal Energetics and coaching offered through Sowilo Society are not a substitute for medical, psychological, or psychiatric care. They are complementary modalities. Clients should continue working with appropriate medical professionals for diagnosis and treatment of any condition.

8. Cookies and website analytics

We use cookies and similar tracking technologies on our website. Types we may use:

- Essential cookies — necessary for the website to function

- Analytics cookies — help us understand how visitors use the site

- Marketing cookies — used to deliver relevant ads and measure campaign performance

- Preference cookies — remember your settings and choices

You can instruct your browser to refuse cookies, though some parts of the site may not function properly without them. If you're visiting from the EU/UK, you'll be shown a cookie consent option allowing you to accept or decline non-essential cookies.

9. Data security

We take reasonable technical and organisational steps to protect your information from misuse, loss, and unauthorised access, including:

- Encryption of data in transit and at rest, where supported by our providers

- Secure storage and restricted access to sensitive/health information

- Working only with reputable, security-conscious third-party providers

- Periodic review of our data-handling practices

- No method of transmission over the internet is 100% secure, but we take this seriously — particularly for health-related information.

10. How long we keep your information

- General account and enquiry information — retained while you're an active client and for a reasonable period afterward

- Health records (Spinal Energetics and coaching intake notes) — retained in line with applicable health record-keeping requirements. (typically around 7 years in Australia)

- Financial and payment records — retained as required for tax and accounting purposes (typically around 5–7 years in Australia)

- Marketing/email data — retained until you unsubscribe or request deletion

When information is no longer needed, we securely delete or de-identify it.

11. Your rights

Depending on where you're located, you may have the right to:

- Access — request a copy of the personal information we hold about you

- Correction — request correction of inaccurate or incomplete information

- Deletion — request deletion of your information, subject to legal/record-keeping requirements

- Restriction — request that we limit how we use your information

- Portability — request your information in a format that can be transferred elsewhere

- Objection — object to certain processing, including for direct marketing

- Withdraw consent — withdraw consent at any time where we rely on it (e.g. sensitive/health information, marketing)

To exercise any of these rights, contact us at https://sowilosociety.com/contact. We'll respond within a reasonable time frame (30 days is standard practice under both APP and GDPR expectations).

Australian complaints: If you're not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

EU/UK complaints: You may contact your local data protection authority.

12. Marketing communications

If you've subscribed to our email list (via Flodesk, Ivorey or similar), you can unsubscribe at any time using the link in any email, by updating your preferences, or by contacting us directly. We won't add you to marketing lists without your opt-in. Even if you opt out of marketing, we may still send essential service-related communications (e.g. booking confirmations).

13. Third-party links

Our website may contain links to third-party websites, plugins, or applications. We're not responsible for the privacy practices of these third parties, and we encourage you to review their privacy policies before providing any information to them.

14. Children

Our services are intended for adults. We don't knowingly collect personal information from anyone under 18. If we become aware that we've collected information from a minor without appropriate consent, we'll take steps to delete it.

15. Changes to this policy

We may update this policy from time to time to reflect changes in our practices or for legal/regulatory reasons. The "last updated" date at the top will reflect the most recent version. We encourage you to review it periodically — continued use of our services after changes indicates acceptance of the updated policy.

16. Contact us

For any privacy questions, requests, or concerns, contact:

Lisa Gaukroger, [email protected], PO BOX 5239 Port Macquarie NSW 2444 Australia, ABN 76454374721