The Wealth Academy

Effective date: 18 August, 2026

1. Our Approach to Privacy

The Wealth Academy Pty Ltd ("The Wealth Academy", "we", "us" or "our") respects the privacy of the individuals who access and use our educational resources and services.

We recognise that many of our educational resources are designed for teenagers and young people. We therefore seek to minimise the personal information we collect, particularly information relating to users under 18 years of age.

Our approach is to collect, hold, use and disclose only personal information that is reasonably necessary for the operation and administration of our educational services or otherwise permitted or required by law.

This Privacy Policy explains how we manage personal information and should be read together with our Terms and Conditions and applicable Intellectual Property and Content Use provisions.

2. Scope of this Privacy Policy

This Privacy Policy applies to personal information collected by The Wealth Academy through:

• The Wealth Academy websites;
• our online course platform and learning services;
• subscriptions and registrations;
• enquiries and communications;
• purchases and transactions;
• surveys or feedback activities;
• authorised institutional arrangements; and
• other educational or digital services operated or administered by The Wealth Academy.

The Wealth Academy also produces educational publications and resources, including Teenfinca®, that may be accessed without the reader providing personal information directly to us.

Where our Content contains links to third-party websites, applications or services, those third parties may collect information under their own privacy policies and terms.

3. Personal Information We May Collect

Depending on the service being used, we may collect information such as:

• name and contact details;
• email address;
• account and login information;
• course enrolment, participation, progress and completion information;
• communications with us, including enquiries and support requests;
• information voluntarily provided through surveys or feedback;
• transaction information associated with purchases or subscriptions; and
• technical information reasonably necessary for website and platform operation, security and performance.

Payment information may be processed by third-party payment providers. The Wealth Academy does not ordinarily store complete credit or debit card details.

We do not seek to collect personal information that is unnecessary for the provision of our educational services.

4. Children and Young People

The Wealth Academy develops educational resources that may be used by children and young people.

We seek to apply a privacy-by-design and data-minimisation approach to young users.

Where practicable:

• young people should be able to access educational information without providing unnecessary personal information;
• only the minimum information necessary to provide or administer an educational service should be collected;
• schools, parents, guardians or authorised organisations should manage identification, permissions and consent where appropriate;
• sensitive information about children and young people should not be requested unless genuinely necessary and lawfully permitted; and
• information relating to young users should not be retained longer than reasonably necessary.

Where consent is legally required and a young person does not have capacity to provide valid consent, consent must be obtained from a parent, guardian or other person authorised to provide it.

Where access is arranged through a school or other authorised educational institution, the institution may be responsible for obtaining appropriate permissions or consents required for participation.

The Wealth Academy does not knowingly sell children's personal information or use children's personal information for targeted advertising.

If we become aware that personal information about a child or young person has been collected unnecessarily or without an appropriate basis, we will take reasonable steps to delete or de-identify that information where appropriate and permitted by law.

The OAIC currently treats "children" for purposes of the developing Children's Online Privacy Code as individuals under 18. The Code remains in development and is due to be registered by 10 December 2026.

5. How We Use Personal Information

Where personal information is collected, we may use it to:

• provide access to educational services and resources;
• establish and administer authorised accounts;
• manage enrolments, subscriptions and purchases;
• provide course-related and service communications;
• respond to enquiries and provide support;
• administer educational participation or completion where required;
• maintain the security and operation of our websites and platforms;
• improve our educational services and user experience;
• maintain appropriate business and transaction records; and
• comply with legal and regulatory obligations.

We will not use personal information for an unrelated purpose unless permitted by law or appropriate consent has been obtained where required.

6. Schools and Other Organisations

The Wealth Academy resources may be made available through schools, educational institutions, employers, community organisations or other authorised organisations.

Where institutional access is provided, we seek to minimise the personal information about individual learners supplied to The Wealth Academy.

Where practicable, the participating organisation should manage student or participant identification, permissions and consent.

The Wealth Academy should receive only information reasonably necessary to establish or administer the relevant educational service.

Where participation or completion information is required by an authorised organisation, the nature of that information should be determined by the relevant arrangement and applicable privacy requirements.

7. Thinkific and Other Service Providers

The Wealth Academy currently uses Thinkific Labs Inc. (Thinkific), a company headquartered in Canada, to host and deliver its online courses and related learning services.

Where an individual creates an account or participates in a course through Thinkific, personal information may be processed through Thinkific's systems and authorised sub-processors. Thinkific currently advises that its production systems and primary customer-data storage infrastructure are located in the United States.

Thinkific engages third-party sub-processors to provide infrastructure, security, communications, analytics, support and other platform functionality. Further information about overseas processing and disclosure is provided in Section 12 — Overseas Processing and Disclosure.

8. Payments and Financial Information

Payments may be processed by third-party payment providers such as Stripe, PayPal or other authorised payment services.

The Wealth Academy does not ordinarily receive or store complete payment-card details.

Payment providers may collect and process information necessary to complete transactions in accordance with their own terms and privacy policies.

9. Cookies, Analytics and Website Information

Our websites and digital platforms may use cookies and similar technologies necessary to:

• enable core website functionality;
• maintain security;
• understand general website usage;
• identify technical problems; and
• improve website and service performance.

We seek to minimise unnecessary tracking, particularly in relation to services intended for or likely to be accessed by young people.

Where analytics services are used, we prefer aggregated or de-identified information where reasonably practicable.

Users may be able to control certain cookies through their browser or device settings, although disabling some cookies may affect website functionality.

10. Direct Marketing

The Wealth Academy may communicate with adults, organisations and authorised subscribers about its educational resources and services where permitted by law.

Recipients may opt out of marketing communications at any time using the unsubscribe facility provided or by contacting us.

We do not knowingly use the personal information of children or young people for targeted direct marketing.

Service communications necessary to administer an account, enrolment, transaction or educational service are not marketing communications.

11. Disclosure of Personal Information

We may disclose personal information where reasonably necessary:

• to service providers assisting us to operate our educational services;
• to an authorised institution where required under an applicable educational arrangement and appropriately disclosed;
• to professional advisers where necessary;
• to protect our legal rights or the security of our services; or
• where required or authorised by law.

The Wealth Academy does not sell personal information.

12. Overseas Processing and Disclosure

The Wealth Academy uses third-party technology and service providers to operate and deliver its websites, online courses and digital educational services. Some of these providers are located outside Australia or may process or store personal information outside Australia.

In particular, The Wealth Academy uses Thinkific Labs Inc. (Thinkific), a Canadian company, to host and deliver its online learning platform. Thinkific currently advises that its production systems and primary customer-data storage infrastructure are located in the United States, including infrastructure provided by Amazon Web Services and Google.

Thinkific also uses authorised sub-processors to provide particular platform, security, communications, support, analytics and other services. Depending on the services used, personal information may be processed by overseas recipients located in countries including the United States, Canada, United Kingdom, Ireland and Spain. Thinkific's sub-processors and their locations may change from time to time.

Other service providers used directly by The Wealth Academy, including payment, communications, technology and support providers, may also process personal information outside Australia. Where practicable, The Wealth Academy will identify the countries in which overseas recipients are likely to be located.

Where Australian privacy law applies to an overseas disclosure of personal information, The Wealth Academy will take reasonable steps to comply with the applicable requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

We seek to minimise the personal information disclosed overseas, particularly personal information relating to children and young people.

13. Security and Retention

We take reasonable technical and organisational measures to protect personal information against misuse, interference, loss and unauthorised access, modification or disclosure.

Access to personal information should be limited to persons who reasonably require it for authorised purposes.

No digital system can be guaranteed to be completely secure.

We seek not to retain personal information for longer than reasonably necessary for the purpose for which it was collected or as required by law.

Where personal information is no longer required, we will take reasonable steps to destroy or de-identify it where required and appropriate.

14. Artificial Intelligence

The Wealth Academy may use artificial intelligence tools to assist with research, educational content development, editing, instructional design and other production activities.

Our general policy is that personal information about learners, particularly children and young people, should not be entered into public or general-purpose generative AI systems unless there is a specific, authorised and privacy-compliant reason for doing so.

Where AI or automated technologies are used in connection with personal information, their use will be assessed against applicable privacy requirements.

The Wealth Academy does not currently intend to use automated systems to make significant decisions about individual learners based on their personal information.

From 10 December 2026, additional APP Privacy Policy requirements will apply to APP entities that arrange for computer programs to use personal information to make decisions that could reasonably be expected to significantly affect an individual's rights or interests.

15. Anonymity and Pseudonyms

Where practicable and lawful, individuals may interact with The Wealth Academy without identifying themselves or may use a pseudonym.

Identification may be required where it is reasonably necessary to provide a particular service, process a transaction, administer an account, issue evidence of completion or comply with legal requirements.

This provision reflects APP 2 and is worth adding to the existing policy.

16. Access and Correction

Individuals may request access to personal information The Wealth Academy holds about them or request correction of information they believe is inaccurate, out of date, incomplete, irrelevant or misleading.

Requests should be made using the contact details below.

We will respond within a reasonable timeframe and in accordance with applicable privacy requirements.

17. Privacy Complaints

If you believe The Wealth Academy has not handled personal information appropriately, you may make a privacy complaint using the contact details below.

We will:

• acknowledge and consider the complaint within a reasonable timeframe;
• request further information where reasonably necessary;
• investigate the matter as appropriate; and
• advise you of the outcome.

If you are not satisfied with our response, you may have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC).

Office of the Australian Information Commissioner

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our educational services, technology, information-handling practices or legal and regulatory requirements.

The current version will be published on The Wealth Academy website and will display its effective date.

We will review this Policy following the finalisation of Australia's Children's Online Privacy Code and make any changes required by the Code if it applies to our services. The OAIC says the Code will apply to specified online services covered by the Privacy Act where the relevant statutory criteria are met; we should therefore not assume at this stage that every TWA resource will automatically fall within its scope.

19. Contact Us

For questions, requests or complaints concerning privacy:

The Wealth Academy Pty Ltd

PO Box 568, Albany Creek QLD 4035

Australia

Email: [email protected]

Further Information

For more information about privacy protections in Australia, visit the Office of the Australian Information Commissioner at www.oaic.gov.au