Marriage Simplified — Privacy Policy

DRAFT — for legal review. NOT legal advice. ⚠️ Must be reviewed by a qualified Australian privacy lawyer before publication.

Effective date: [DATE]

Operator: Gosling International (ABN 28 219 744 700), Queensland, Australia ("we", "us", "our").

Product: Marriage Simplified — an online AI-powered relationship-coaching chat service ("the Service").

We are committed to protecting your privacy and handling your personal and health information in accordance with the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs). Because the Service involves information about your mental and relational wellbeing, we treat your information to the highest standard required for sensitive and health information, regardless of our business size.

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1. What this policy covers

This policy explains what information we collect, why, how we use and protect it, when we share or de-identify it (including our communal-learning model), your rights, and how to contact us or complain.

2. Important: what Marriage Simplified is and is not

• The Service provides AI-delivered relationship coaching, education and support.
• It is not therapy, psychology, medical treatment, or a registered health service, and the AI is not a registered psychologist or a human counsellor.
• It is not a crisis or emergency service. If you are in danger or crisis, see Section 12.

3. The information we collect

We collect:

• Account information: name or chosen display name, email address, age confirmation, and authentication details.
• Sensitive information (health information): the content of your chat conversations with the AI, which may include information about your mental health, relationships, family, ADHD, autism, and similar topics.
• Counsellor case notes: where you also engage with our human counsellor, confidential case notes created by the counsellor about your sessions.
• Information about other people: you may describe your partner, children or others. Information about them may also be personal or sensitive information (see Section 9).
• Technical/usage information: device, log, and usage data needed to operate and secure the Service.

We collect this information directly from you (and, for case notes, from our human counsellor). We collect only what is reasonably necessary to provide and improve the Service.

4. Consent to collect sensitive/health information

Because chat content and case notes are sensitive information, we collect them only with your express consent, given at sign-on and able to be withdrawn (see Section 8 and the separate Consent & Disclaimer you accept before using the Service). Your consent is voluntary, specific and informed.

5. Why we collect and how we use your information

We use your information to:

• provide the AI coaching chat to you (our primary purpose);
• enable our human counsellor to support you and maintain case notes;
• maintain, secure and improve the Service;
• comply with legal obligations and respond to safety risks (see Section 12);
• with your separate consent and/or after robust de-identification, improve the AI so that anonymised learnings can help other couples (our communal-learning model — Section 7).

We do not sell your information. We do not use it for third-party advertising.

6. Communal learning — how we share learnings without sharing you

We believe insights from real relationship challenges can help others. To do this safely:

• We will use your data to inform the AI for other couples ONLY where (a) you have given separate, opt-in consent (the "communal-learning" toggle), and/or (b) the data has been robustly de-identified before any such use, in line with OAIC de-identification guidance.
• We never show one couple's identifiable information to another couple. Cross-couple learnings are abstracted, aggregated patterns only — never your names, your partner's name, or details that could identify you.
• De-identification means removing names and identifying details and reducing re-identification risk to a very low level. Once robustly de-identified, that information is no longer "personal information" about you.
• The communal-learning toggle is OFF by default and you can turn it off at any time. Turning it off stops future communal use; data already robustly de-identified and absorbed into the AI may not be separately retrievable.

7. When we disclose your information

We may disclose personal information to:

• service providers / processors who host, secure and operate the Service (e.g. cloud hosting and AI processing providers), under contract to protect your information;
• our human counsellor, where you engage that service;
• authorities or support services, where reasonably necessary to lessen or prevent a serious threat to life, health or safety, or where required or authorised by law (including mandatory reporting — Section 12).

We do not otherwise disclose your information without your consent.

8. Overseas disclosure & data location (APP 8)

We aim to store and process your data within Australia wherever practicable. Some of our service providers (for example, cloud infrastructure and AI processing) may store or process data in, or access it from, [LIST COUNTRIES — e.g. United States / EU].

Before disclosing personal information overseas we take reasonable steps to ensure overseas recipients handle it consistently with the APPs, and we remain accountable for their handling of it. Where any provider would otherwise use your data to train their own systems, we contractually disable that. ⚠️ Operator to complete the country list and confirm Cloudflare / LLM data-residency configuration before publishing.

9. Withdrawing consent, retention and deletion

• You can withdraw consent (including communal-learning consent) and request access, correction or deletion of your identifiable information at any time (Section 11).
• We retain your information only as long as necessary for the purposes above or as required by law and professional record-keeping obligations. Counselling case notes may be retained for a minimum period required by professional standards (commonly several years). ⚠️ Operator/lawyer to confirm exact retention period.
• When information is no longer needed and no legal obligation requires us to keep it, we destroy it or de-identify it.

10. Information about other people (e.g. your partner)

When you share information about your partner, children or others, you should only share what is reasonable. Those people may also have privacy rights in that information. If someone contacts us about information you have shared about them, we will handle it in accordance with the Privacy Act. ⚠️ Couples/third-party handling to be confirmed with lawyer.

11. Security of your information (APP 11)

We take reasonable steps to protect your information appropriate to its sensitivity, including encryption in transit and at rest, strict access controls and least-privilege access to counsellor case notes, audit logging, separation of identified data from our de-identified learning pool, and vendor security due diligence. No system is perfectly secure, but we maintain safeguards proportionate to the high sensitivity of this data.

12. Your rights — access and correction (APP 12 / 13)

You may request access to the personal information we hold about you and ask us to correct it. We will respond within a reasonable time and explain any refusal. Some health-information exceptions may apply (for example where access could pose a serious threat to life, health or safety); in those cases we will involve our human counsellor.

13. Safety and legal disclosures

If we reasonably believe there is a serious and imminent threat to your life, health or safety or that of another person, or where we are required or authorised by law (including child-safety mandatory reporting in Queensland), we may use or disclose your information to prevent or lessen that threat or to comply with the law. See the in-product Safety & Crisis information and the Consent & Disclaimer.

14. Data breaches

We comply with the Notifiable Data Breaches scheme. If a data breach is likely to cause you serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) as required by law.

15. Changes to this policy

We may update this policy. Material changes will be notified in-product. The "Effective date" shows the current version.

16. How to contact us or complain

To exercise your rights, ask a question, or make a privacy complaint, contact us at: [CONTACT EMAIL / POSTAL ADDRESS — operator to insert].

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au · 1300 363 992.

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References: Privacy Act 1988 (Cth) and Australian Privacy Principles; OAIC Guide to Health Privacy; OAIC de-identification guidance. This draft requires legal review before use.