Privacy Policy

Who are we

The App is operated by Studio Subs Pty Ltd (ACN 694 386 180 / ABN 20 694 386 180), an Australian company with its registered office in Australia ("Studio Subs", "we", "us" or "our").

Studio Subs operates an online platform that enables fitness studios, gyms, wellness spaces and other venues ("Studios") to connect with fitness instructors and professionals ("Instructors") to arrange and manage one-off or short-term cover shifts for classes, activities, events and services (the "Purpose").

The App may contain links to third-party websites or services operated by partners, advertisers or affiliates. Those third parties have their own privacy policies, and we are not responsible for their privacy practices. We encourage you to review their policies before providing personal information.

What data do we collect about you?

We may collect and process the following categories of personal data:

Identity Data

First name, last name, title, date of birth, gender.

Contact Data

Email address, telephone number, business or studio address, personal address.

Financial Data

Subscription billing information for Studios (processed by Apple Inc. via Apple's in-app purchase system and Google LLC via Google Play Billing, and their affiliated entities).

Studio Subs does not collect or store bank account details for payments between Studios and Instructors.

Studio Subs does not collect, store, or have access to full payment card details. Payment processing is handled directly by Apple Inc. and Google LLC via their respective in-app purchase systems.

Device Data

Information about the device you use to access the App, including device type, unique device identifiers, operating system, browser type, mobile network information, IP address, and time zone settings.

Content Data

Information you upload or provide through the App, including:

• Profile photos
• Qualifications, certifications and licences
• Availability and schedules
• In-app messages and communications
• Other content you choose to upload

Usage Data

Information about how you use the App, including access times, features used, traffic data, and interaction data.

Marketing and Communications Data

Your preferences regarding marketing communications and how you choose to receive them.

Location Data

Your approximate location, where enabled (you can turn this off in your device settings).

We do not intentionally collect sensitive information, including health data, biometric data, racial or ethnic origin, religious beliefs, political opinions, trade union membership, or criminal history.

How we collect personal information

We collect personal information when you:

• Download, access or use the App
• Register for an account or create a profile
• Upload content or communicate through the App
• Contact us via email or other channels
• Interact with our website, communications or support services

We take reasonable steps to notify you at or before the time of collection, or as soon as practicable afterwards, of the purposes for which your personal information is collected.

How and why do we process your data?

"Processing" includes collecting, storing, using, disclosing, updating and deleting personal information.

We only use personal information where permitted under the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

You can update your profile information at any time through the App.

We process billing and subscription-related information to manage Studio subscriptions and access to Platform features.

Legal bases for processing

We will only use your personal data where permitted under Australian law, including where:

• You have given consent
• It is necessary to perform a contract with you
• It is required for our legitimate business interests (and those interests do not override your rights)
• We are required to comply with a legal or regulatory obligation

You may withdraw consent at any time by contacting us or updating your settings, noting this may affect your ability to use the App.

Purposes for which we use your personal data

Profile visibility and communications

• Instructor profiles are visible to Studios seeking cover shifts through the App.
• Certain information may only become visible once a shift is accepted or engagement confirmed.
• Studios and Instructors acknowledge that information shared through the App may be viewed by other users for the Purpose of arranging cover shifts.

Automated decision-making

We may use automated systems to assist with the operation of the App, including matching Instructors with relevant Shifts based on qualifications, availability, and location.

Important information about automated decisions:

• Where automated processes make decisions that significantly affect you, we will tell you that this is the case and provide information about the logic involved.
• You have the right to request human review of any automated decision that significantly affects you.
• To request human review or more information about automated decision-making, contact us at admin@studiosubs.com

This section is provided in accordance with the requirements of the Privacy and Other Legislation Amendment Act 2024 (Cth).

Marketing communications

We will only send you direct marketing communications by email or SMS where you have provided consent in accordance with the Spam Act 2003 (Cth).

You can opt out of marketing communications at any time by:

• Using the unsubscribe link in messages
• Updating your preferences in the App
• Contacting us directly

We will process unsubscribe requests within 5 business days as required by law.

We do not sell your personal data to third parties.

Sharing your personal data with third parties

We only share personal data where necessary for the Purpose of the App or as required by law.

This may include:

• Sharing instructor profiles with studios seeking cover
• Sharing studio details with instructors who accept shifts
• Apple Inc. and its affiliated entities, for the purpose of processing subscription payments, managing subscriptions, and handling billing through Apple's in-app purchase system
• Google LLC and its affiliated entities, for the purpose of processing subscription payments, managing subscriptions, and handling billing through Google Play Billing

We may also disclose personal information to:

• Technology service providers (hosting, analytics, security)
• Payment processors (for Studio subscription billing only, including Apple Inc. and Google LLC)
• Professional advisers (legal, accounting, insurance)
• Regulators or authorities where legally required

Apple Inc. and Google LLC act as independent controllers of personal data processed through their respective payment platforms and handle personal information in accordance with their own privacy policies.

We take reasonable steps to ensure third parties handle personal information securely and in accordance with Australian privacy law.

Overseas data transfers

Your personal data may be stored or processed overseas where our service providers operate. Our primary service providers are located in:

• Australia (primary data storage and infrastructure including Supabase)
• United States (cloud infrastructure providers, transactional email delivery and push notification services including Resend, Expo, and payment processing services provided by Apple Inc. and Google LLC)
• Ireland (payment processing and support services provided by Apple Distribution International Ltd and Google Ireland Limited)
• Other countries (where our service providers and their sub-processors maintain operations or infrastructure from time to time)

If you purchase a subscription through the App, Apple Inc. (for iOS users) and Google LLC (for Android users) will process your payment and related subscription data in accordance with their own privacy policies.

Where your personal information is transferred to an overseas recipient, we take reasonable steps to ensure compliance with the Australian Privacy Principles, including by:

• Entering into contractual arrangements requiring the recipient to handle information in accordance with Australian privacy law; or
• Satisfying ourselves that the recipient is subject to laws substantially similar to the Australian Privacy Principles.

If you have concerns about overseas data transfers, please contact us.

Note: The Australian Government may designate certain countries as having adequate privacy protections under regulations made pursuant to the Privacy and Other Legislation Amendment Act 2024. We will update this policy to reflect any such designations.

Keeping your data secure

We store data on secure, cloud-based servers with appropriate technical and organisational safeguards.

You are responsible for keeping your login credentials confidential. Please do not share your password with anyone.

We have procedures in place to respond to suspected data breaches and will notify affected users and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth), where required by law.

Cookies and similar technologies

We use cookies and similar technologies to:

• Operate and secure the App
• Remember user preferences
• Improve performance and functionality

We do not use cookies for third-party advertising purposes.

Cookies are small text files placed on your device that help us provide and improve the App. You can control cookies through your browser settings, but disabling cookies may affect App functionality.

Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law.

In determining retention periods, we consider:

• Nature and sensitivity of the data
• Risk of harm from unauthorised use
• Legal and regulatory requirements

You may request deletion of your personal data by contacting us (see 'Your rights' below).

If an account remains inactive for twelve (12) months, it may be treated as expired and personal data may be deleted. We will notify you by email at least 30 days before deletion.

In some cases, we may anonymise data for analytics or research purposes, in which case it may be retained indefinitely.

Your rights

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the right to:

• Request access to your personal data (APP 12)
• Request correction of inaccurate or incomplete data (APP 13)
• Request deletion of your personal data (subject to legal obligations)
• Withdraw consent where processing is based on consent
• Request human review of automated decisions that significantly affect you

There is no fee for exercising your rights.

We will respond to access and correction requests within a reasonable period, and in any event within 30 days of receiving your request.

To make a request, contact us at admin@studiosubs.com

Children

The App is not intended for individuals under 18 years of age, and we do not knowingly collect personal information from minors.

If we become aware that we have collected personal information from a minor, we will take steps to delete that information as soon as practicable.

Changes of ownership

If ownership or control of Studio Subs changes, your personal data may be transferred to the new owner so they can continue operating the App in accordance with this Privacy Policy. We will notify you of any such transfer.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted within the App or on our website and, where appropriate, notified to you by email.

Material changes will be notified at least 30 days before they take effect.

Your duty to keep information accurate

Please ensure that your personal data remains accurate and up to date. You can update most information directly through the App.

Questions and complaints

If you have any questions or complaints about this Privacy Policy or how we handle personal data, please contact us at:

Email: admin@studiosubs.com

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

• Office of the Australian Information Commissioner
• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Postal Address: GPO Box 5218, Sydney NSW 2001

Summary of your rights under the Privacy Act 1988 (Cth)