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Discover Your Change Archetype™

The Hamilton Framework

Privacy Policy

Effective as of 6 September 2026          

  • INTRODUCTION
    • This document sets out the privacy policy of Simone Hamilton (ABN 70 254 234 251), trading as The Hamilton Framework (referred to in this privacy policy as ‘we’, ‘us’, or ‘our’).
    • We take our privacy obligations seriously and we’ve created this privacy policy to explain how we store, maintain, use and disclose personal information.
    • We are committed to preventing serious invasions of privacy and ensuring the protection of your personal information, so you can contact us using the details below if you have any questions or concerns.
    • By providing personal information to us, you consent to our storage, maintenance, use and disclosure of that personal information in accordance with this privacy policy. Where we collect sensitive information (including health information), we will obtain your separate, express consent as required by the Australian Privacy Principles.
    • We may change this privacy policy from time to time by posting an updated copy on our website . Where changes are material, we will take reasonable steps to notify you (for example, by email or a prominent notice on our website). We encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.
  • TYPES OF PERSONAL INFORMATION WE COLLECT
    • The personal information we collect may include the following:
      • name;
      • mailing or street address;
      • email address;
      • social media information;
      • telephone number and other contact details;
      • age;
      • date of birth;
      • credit card or other payment information;
      • information about your business or personal circumstances;
      • information in connection with client surveys, questionnaires and promotions;
      • your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information;
      • information about third parties; and
      • any other information provided by you to us via our website or our online presence, or otherwise required by us or provided by you. For details about the sensitive information (including health information) we collect, see Section 3 below.
    • SENSITIVE INFORMATION
      • Some of the personal information we collect is 'sensitive information' under the Privacy Act, which receives a higher level of protection. This includes health-related and behavioural information (for example, information about smoking habits and quit attempt history, vaping device usage and nicotine concentration, alcohol use, GLP-1 or other medication type, dosage and duration, weight history, and self-reported psychological measures such as stress, energy, self-trust and confidence ratings), and results from our archetype assessments and intake questionnaires. We only collect sensitive information with your consent, which we obtain separately via our Consent Form, and we only use and disclose it for the purposes you have consented to.
    • HOW WE COLLECT PERSONAL INFORMATION
      • We may collect personal information either directly from you, or from third parties, including where you:       complete our Discover Your Change Archetype™ assessment, or any program entry survey, module check-in, or follow-up survey as part of your participation in one of our programs - including follow-up surveys sent automatically at set intervals after you complete a program;
      • are referred to us by a general practitioner or other healthcare or allied health provider, or a parent or guardian provides information on your behalf if you are a minor;
      • contact us through our website;
      • receive goods or services from us;
      • submit any of our online sign up forms;
      • communicate with us via email, telephone, SMS, social applications (such as LinkedIn, Instagram or Meta ) or otherwise;
      • interact with our website, social applications, services, content and advertising; and
      • invest in our business or enquire as to a potential purchase in our business.
    • We collect and store personal information through the platforms we use to deliver our programs, including Kajabi, ScoreApp, Practice Better, Typeform, and automation and data management tools such as Zapier, Google Sheets, Airtable and SmartSuite.
    • We may also collect personal information from you when you use or access our website or our social media pages. This may be done through use of web analytics tools, ‘cookies’ or other similar tracking technologies that allow us to track and analyse your website usage. Cookies are small files that store information on your computer, mobile phone or other device and enable the creator of the cookie to identify when you visit different websites. We use both first-party and third-party cookies for analytics and functionality purposes. If you do not wish information to be stored as a cookie, you can disable cookies in your web browser or adjust your cookie preferences on our website.
    • We may use Google Analytics to collect and process data, including when you use third party websites or apps. To find out more, see How Google uses data when you use our partners’ sites or apps.
  • USE OF YOUR PERSONAL INFORMATION
    • We collect and use personal information for the following purposes:
      • to provide goods, services or information to you;
      • for record keeping and administrative purposes;
      • to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing goods or services to you, or to referring healthcare practitioners with your express consent, provided those recipients are bound by confidentiality and privacy obligations no less protective than this policy;
      • to improve and optimise our service offering and customer experience, including by using de-identified and aggregated data for internal research, program evaluation, and academic or clinical research collaborations in Australia (subject to ethics approval where applicable);
      • to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
      • to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act 2003 (Cth) (Spam Act)). We will not use sensitive information for direct marketing purposes without your express consent. In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
      • to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you, including automated program delivery communications such as module completion prompts, check-in surveys, and post-program follow-up surveys (which are part of our service delivery and are not direct marketing); and
      • to consider an application for employment or engagement from you, where you apply to work with us.
    • We may disclose your personal information to cloud providers, contractors and other third parties located inside or outside of Australia. If we do so, we will take reasonable steps to ensure that any overseas recipient has similar legal safeguards and deals with such personal information in a manner consistent with how we deal with it.
    • We may use your responses to check-in surveys to identify when additional personal support may be helpful, and may reach out to you directly as part of our clinical care and program delivery (not for marketing purposes).
  • AUTOMATED PERSONALISATION
    • When you complete our Discover Your Change Archetype™ assessment, we use an automated process to analyse your responses and identify your Change Archetype     . We use this to personalise the content, communications and program recommendations you receive. This automated process does not, on its own, make any decision that has a legal or similarly significant effect on you — for example, it does not solely determine your eligibility to access our programs, or affect pricing. Any clinical decisions are made by a qualified practitioner with reference to your individual circumstances. If you have questions about how your Change Archetype was determined, you're welcome to contact us at [email protected].
  • SECURITY
    • We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal information. We will take reasonable steps to destroy or permanently de-identify personal information when it is no longer needed for the purposes for which it was collected, or as otherwise required by law. 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 in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth).
  • LINKS
    • Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.
  • REQUESTING ACCESS OR CORRECTING YOUR PERSONAL INFORMATION
    • If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below, including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information, and where this occurs, we will explain why. We will deal with all requests for access to personal information within 30 days of receiving the request.
    • If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.
  • COMPLAINTS
    • If you wish to complain about how we handle your personal information or believe your privacy has been seriously invaded, please contact us using the details provided below with your name and contact details. We will investigate your complaint promptly and respond within 30 days. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
  • CONTACT US
    • For further information about our privacy policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below (including by post if you prefer):
    • Name: Simone Hamilton
    • Email: [email protected]
    • If you are not satisfied with our response to your complaint, you may contact the Office of the Australian Information Commissioner (OAIC):
    • Website: www.oaic.gov.au (including the online privacy complaint form)
    • Phone: 1300 363 992
    • Post: GPO Box 5218, Sydney NSW 2001