PRIVACY POLICY

Shine to Success Collective Pty Ltd 54 684 627 058 trading as Echelon System ("we", "us", "our") operates the Echelon System platform and website located at runonechelon.com ("the System"). We are committed to protecting your personal information and handling it in a transparent, secure, and lawful manner consistent with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

By using our website, purchasing our services, or accessing the System, you acknowledge that you have read and agree to this Privacy Policy.

1. Who This Policy Applies To

This policy applies to all individuals whose personal information we collect, including:

* Visitors to runonechelon.com

* Prospective and current clients of the Echelon System

* Individuals who contact us via email, social media, or our diagnostic tool

If you are located in the European Union, United Kingdom, or California (USA), additional rights and obligations may apply to you. These are noted where relevant throughout this policy.

2. Information We Collect

We may collect the following categories of personal information:

* Contact details: name, email address, phone number, billing address

* Account information: username, password, login activity

*Payment information: processed securely through third-party payment processors. We do not store card details.

* System data: usage activity, license details, affiliate tracking

* Marketing preferences: opt-in status, cookie consent choices

*Communications: messages you send us via email or support channels

We collect personal information only by lawful and fair means. We will not collect more personal information than is necessary for the purposes described in this policy.

3. How We Use Your Information

We collect and use your personal information for the following purposes and, where GDPR applies, on the lawful bases indicated:

Purpose

* Providing, maintaining, and improving the System (Lawful basis: Contract / Legitimate interests)

* Processing payments and managing licenses (Lawful basis: Contract)

* Delivering onboarding and technical support (Lawful basis: Contract)

* Sending transactional emails, including system updates, billing confirmations, and license notifications (Lawful basis: Contract)

* Complying with legal and regulatory obligations (Lawful basis: Legal obligation)

* Protecting the security and integrity of our systems (Lawful basis: Legitimate interests)

We will not use your personal information for any purpose that is incompatible with the purposes for which it was collected without your consent.

4. Email Communication Policy

We will only send you emails that are directly related to your use of the Echelon System, including:

* System and account notifications

* Billing confirmations and license renewals

* Onboarding and technical support communications

We will never:

* Use your email address to send promotional offers for unrelated products or services

* Sell, rent, or share your email address for marketing purposes

Where we send any commercial electronic message, we will comply with the Spam Act 2003 (Cth), including by providing a functional unsubscribe mechanism in every message and honouring unsubscribe requests promptly.

Marketing emails relating to integrated ecosystem subscriptions or partner programs are sent only by the relevant partner or license holder, not by Shine to Success Collective Pty Ltd.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on runonechelon.com for the following purposes:

* Maintaining secure user sessions

* Tracking affiliate commissions

* Measuring website performance and analytics

Where required by applicable law, we will obtain your consent before placing non-essential cookies on your device. You may withdraw consent or manage your cookie preferences at any time using the cookie consent tool on our website.

For full details of the cookies we use and how to manage them, see our Cookie Policy https://runonechelon.com/cookie

6. Disclosure of Your Information

We may disclose your personal information to the following categories of third parties:

* Payment processors: to complete and verify transactions (including Stripe or similar processors operating in the United States)

* Technology and operating system providers: including Echelon System, who provide the CRM, automation, and funnel operating system underlying the System. Echelon System processes data in the United States.

* Email and communication platforms: to deliver transactional messages

* Regulators and law enforcement: where we are required to do so by law

We will never sell your personal information to third parties.

Before disclosing your personal information to an overseas recipient, we take reasonable steps to ensure that the overseas recipient handles your information in a manner consistent with the APPs (APP 8.1), including by using data processing agreements and contractual clauses with our technology partners.

Our primary technology partners process data in the United States. If you are located in the EU or UK, transfers to the United States are governed by appropriate safeguards including Standard Contractual Clauses where applicable.

7. Your Privacy Rights

Depending on your location, you may have the right to:

* Access the personal information we hold about you

* Correct or update inaccurate personal information

* Request deletion of your personal information (subject to our legal retention obligations)

* Withdraw consent for processing activities based on consent

* Request a portable copy of your personal information (EU/UK users)

* Object to or restrict certain types of processing (EU/UK users)

* Opt out of the sale or sharing of personal information (California users)

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au. EU and UK users may also contact their local data protection supervisory authority.

8. Data Retention

We retain your personal information for the following periods:

* Client account and operational data: for the duration of your active license and for 90 days following cancellation or expiry, after which it is deleted or de-identified

* Financial and transactional records: for 7 years following the relevant transaction, in accordance with Australian taxation and accounting obligations

* Communications and support records: for 2 years from the date of the communication, or longer if required for the resolution of a dispute

Where personal information is no longer required for the purpose for which it was collected and no legal obligation requires us to retain it, we will take reasonable steps to destroy or de-identify it (APP 11.2).

9. Data Security

We take reasonable technical and organisational measures to protect your personal information from misuse, interference, loss, unauthorised access, modification, and disclosure. These measures include:

* Encryption of data in transit using TLS/SSL

* Access controls limiting data access to authorised personnel only

* Use of password-protected systems and multi-factor authentication where available

* Reliance on third-party platforms that hold industry-standard security certifications

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the OAIC as required under the Notifiable Data Breaches (NDB) scheme. Where GDPR applies, we will also notify the relevant supervisory authority within 72 hours of becoming aware of the breach.

10. International Data Transfers

Your personal information may be transferred to and processed in countries outside Australia, including the United States, where our technology partners (including Echelon System) operate their operating system.

We take reasonable steps to ensure that overseas recipients handle your personal information in a way that is consistent with the APPs. Where we transfer personal data of EU or UK data subjects internationally, we rely on appropriate safeguards including Standard Contractual Clauses.

11. Children

The Echelon System is not directed at individuals 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 so we can delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. When we make material changes, we will update the "Last Updated" date at the top of this page and notify you by email or a prominent notice on our website where required.

Continued use of the System after the effective date of any changes constitutes acceptance of the updated policy.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or our handling of your personal information, please contact us:

Shine to Success Collective Pty Ltd

Trading as: Echelon System

ABN: 54 684 627 058

Registered Address: Shell Cove NSW 2529

Email: [email protected]

Website: runonechelon.com