Privacy Policy

The Outlet by KINSPACE

Effective Date: October 1, 2025
Last Updated: October 1, 2025

At KINSPACE, your privacy matters to us. The Outlet is designed to help you navigate tough workplace conversations with confidence. And we want you to feel just as confident about how we handle your personal information.

On The Edge Pty Ltd (ABN: 98 571 677 108) ("we," "our," "us," or "KINSPACE") is committed to protecting your privacy and ensuring transparency in how we collect, use, and safeguard your personal information when you use The Outlet mobile application ("the App").

This Privacy Policy explains our practices regarding your personal data and your rights under the Australian Privacy Act 1988 (including the Australian Privacy Principles), the EU General Data Protection Regulation (GDPR), and international human rights standards.

By using The Outlet, you agree to this Privacy Policy. If you don't agree, please don't use the App.

1. Information We Collect

1.1 Information You Provide Directly

When you use The Outlet, we collect:

Account Information: Name, email address, workplace role or title (optional), and password

Conversation Data: Text inputs you provide when using our AI coaching features, including:

• Pre-conversation planning notes
  
• Real-time conversation guidance requests
  
• Post-conversation reflections
  
• Practice role-play scenarios
  

Feedback and Communications: Your responses to surveys, feedback forms, support requests, and communications with us.

Profile Preferences: Settings, notification preferences, and coaching customisation options

1.2 Information Collected Automatically

Data Linked to Your Identity:

Usage Data: Features accessed, session duration, interaction patterns with the App, and frequency of use (linked to your account to provide personalised coaching)

Log Data: Access times, App crashes, and performance data (linked to help us debug issues you report)

Data Not Linked to Your Identity:

Device Information: Device type, operating system version (collected in aggregate form only)

Analytics Data: Aggregated usage statistics to improve App functionality (anonymised and not linked to your account)

1.3 Information We Do Not Collect

• We do not collect precise geolocation data
  
• We do not access your camera or photo library without explicit permission
  
• We do not collect biometric data
  
• We do not record audio or video without your explicit consent
  

2. How We Use Your Information

We use your personal information for the following purposes:

2.1 Primary Service Delivery

• Provide AI-powered coaching and conversation guidance
  
• Generate personalised recommendations for handling high-stakes conversations
  
• Maintain and improve the quality of our AI responses
  
• Enable practice scenarios and role-playing features
  

Important Note About Workplace Conversations: While The Outlet is designed to help with workplace conversations, we do not share your conversation content with your employer or any third parties (except our AI service providers as necessary to deliver the coaching service). Your conversations remain private.

2.2 App Improvement and Development

• Analyse usage patterns to enhance user experience
  
• Develop new features and functionality
  
• Conduct research to improve AI coaching effectiveness
  
• Fix bugs and optimise performance
  

2.3 Communication

• Send service-related notifications and updates
  
• Respond to your enquiries and support requests
  
• Provide important information about the App
  
• Send optional newsletters or coaching tips (with your consent)
  

2.4 Legal and Security

• Comply with legal obligations
  
• Protect against fraud, security threats, and abuse
  
• Enforce our Terms of Service
  
• Resolve disputes
  

Legal Basis for Processing (GDPR):

• Performance of contract (providing the App services)
  
• Legitimate interests (improving services, security)
  
• Consent (marketing communications, optional features)
  
• Legal obligation (compliance with laws)
  

3. AI Processing and Data Security

3.1 AI Service Providers

The Outlet uses third-party AI services to power our coaching features. Your conversation inputs are processed by:

AI Service Provider(s): OpenAI (GPT-4) and Anthropic (Claude)

Purpose: To generate coaching guidance, conversation suggestions, and practice scenarios

Data Handling: Conversation data is transmitted securely via encrypted connections

Retention by AI Providers: Data is not retained beyond 30 days and is used only for abuse monitoring, not for training AI models

Third-Party Privacy Policies:
OpenAI: https://openai.com/privacy/
Anthropic: https://www.anthropic.com/privacy

We select AI providers that maintain strong security standards and data protection practices ensuring they:

• Process data only according to our instructions
  
• Implement appropriate security measures
  
• Do not use your data to train their general AI models without your separate explicit consent
  
• Delete data according to our retention requirements
  

3.2 Your Control Over AI Processing

You have the following controls over how your conversation data is used:

Session History: You can delete individual conversation sessions at any time via the in-app history feature (Settings → Conversation History → Swipe to Delete)

AI Training Opt-Out: Your conversation data is NOT used to train AI models by default. If you choose to help improve The Outlet by contributing anonymised data, you can opt-in via Settings → Privacy → Contribute to Improvement

Data Minimisation: We only send the necessary context to our AI providers to generate relevant coaching responses. We do not share your full profile or account history with each request

Temporary Processing: AI providers process your inputs only to generate responses and do not retain your conversation data beyond what is necessary for service delivery

3.3 Data Security Measures

We implement industry-standard security measures including:

• End-to-end encryption for data in transit (TLS 1.3)
  
• Encryption for data at rest (AES-256)
  
• Secure authentication and password hashing (bcrypt)
  
• Regular security audits and vulnerability assessments
  
• Access controls limiting employee access to personal data
  
• Secure cloud infrastructure with ISO 27001 certified providers (Amazon Web Services)
  
• Certificate pinning to prevent man-in-the-middle attacks
  
• Rate limiting and abuse detection systems
  

Data Breach Response: In the unlikely event of a data breach affecting your personal information, we will notify you and relevant authorities within 72 hours as required by law.

4. Data Sharing and Disclosure

We DO NOT sell your personal information. Ever.
Whilst we keep your data private, there are limited circumstances where we share information with trusted partners to deliver our services:

4.1 We Share Information With:

Service Providers: Trusted third parties who assist us with:

• Cloud hosting and storage (Amazon Web Services)
  
• AI processing and machine learning (OpenAI, Anthropic)
  
• Analytics and app performance monitoring (Google Analytics - optional, can be disabled)
  
• Customer support tools (Intercom)
  
• Payment processing (Stripe - if applicable)
  

All service providers are contractually bound to protect your data and use it only for specified purposes through Data Processing Agreements (DPAs).

Legal Requirements: We may disclose information when required to:

• Comply with legal obligations, court orders, or subpoenas
  
• Protect our rights, property, or safety
  
• Prevent fraud or security threats
  
• Comply with law enforcement requests where legally required
  

4.2 We Do Not:

• Sell your personal information to third parties
  
• Share your conversation data with your employer without explicit consent
  
• Use your data for advertising purposes or targeted advertising
  
• Share identifiable data with AI training datasets without your explicit opt-in consent
  
• Track you across other companies' apps or websites
  

5. Data Retention

Account Data: Retained whilst your account is active and for 12 months after account deletion (unless longer retention is required by law)

Conversation Data: Retained for 24 months to enable historical reflection features, then automatically deleted (you may delete sooner via in-app settings at any time)

Analytics Data: Aggregated and anonymised data may be retained indefinitely for product improvement

Deleted Data: Securely purged from our active systems within 30 days of deletion request
Backup Systems: Data in backups is deleted within 90 days of account deletion

You can request early deletion of specific conversation data or your entire account at any time through Settings → Privacy or by contacting connect@kinspace.co>connect@kinspace.co>connect@kinspace.co.>connect@kinspace.co.

6. Your Privacy Rights

6.1 Australian Privacy Rights (APP)

If you are in Australia, you have the right to:

• Access your personal information
  
• Correct inaccurate or incomplete information
  
• Request deletion of your information (subject to legal retention requirements)
  
• Opt-out of direct marketing communications
  
• Make a complaint to the Office of the Australian Information Commissioner (OAIC)
  

OAIC Contact:
Website: www.oaic.gov.au
Phone: 1300 363 992
Email: enquiries@oaic.gov.au

6.2 GDPR Rights (EU/EEA/UK Users)

If you are in the EU, EEA, or UK, you have additional rights:

• Right to Access: Obtain a copy of your personal data
  
• Right to Rectification: Correct inaccurate data
  
• Right to Erasure: Request deletion of your data ("right to be forgotten")
  
• Right to Restriction: Limit how we process your data
  
• Right to Data Portability: Receive your data in a structured, machine-readable format (JSON)
  
• Right to Object: Object to processing based on legitimate interests
  
• Right to Withdraw Consent: Withdraw consent for consent-based processing at any time
  
• Right to Lodge a Complaint: Contact your local data protection authority
  
• Rights Related to Automated Decision-Making: Right to explanation of AI-driven decisions and human review where appropriate
  

EU Representative: Not applicable - we do not have an establishment in the EU

EU Supervisory Authorities: Find your local authority at https://edpb.europa.eu/about-edpb/board/members_en

6.3 Exercising Your Rights

To exercise any of these rights:
In-App Settings:

Data Access/Download: Settings → Privacy → Download My Data (JSON format)

Data Deletion: Settings → Privacy → Data Rights → Delete Specific Data

Account Deletion: Settings → Account → Delete Account (this removes your account and all associated data)

Marketing Preferences: Settings → Notifications → Email Preferences

Email: connect@kinspace.co
Mail:
KINSPACE Pty Ltd
521/6 Sedgeland Drive
Sunshine Coast, QLD 4567
Australia

We will respond to your request within 30 days (or as required by applicable law). We may need to verify your identity before processing your request to protect your privacy and security.

7. Children's Privacy

The Outlet is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have collected data from a child under 18, we will delete it promptly.

If you believe we have inadvertently collected information from a minor, please contact us immediately at connect@kinspace.co.

8. International Data Transfers

Your information may be transferred to and processed in countries outside Australia, including:

United States (AI processing via OpenAI and Anthropic, cloud hosting via Amazon Web Services)
European Union (backup data centres)

We ensure adequate protections through:

• Standard Contractual Clauses (SCCs) approved by the European Commission
  
• Data Processing Agreements with all third-party processors
  
• Compliance with Australian cross-border disclosure requirements (APP 8)
  
• Additional safeguards such as encryption in transit and at rest
  

For EU/EEA data subjects, we will periodically conducted Transfer Impact Assessments to ensure your data remains protected when transferred outside the EEA.

9. Cookies and Tracking Technologies

The Outlet app uses minimal tracking technologies:

Essential: Required for authentication and basic functionality (session tokens)

Analytics: To understand app usage (you may opt-out in Settings → Privacy → Share Analytics)

Preferences: To remember your settings (stored locally on device)

We do not use advertising cookies or trackers. We do not track you across apps and websites owned by other companies.

App Tracking Transparency (iOS): The Outlet does not track you for advertising purposes. If we ever introduce cross-app or cross-site tracking, we will request your explicit permission via Apple's App Tracking Transparency prompt.

iOS Permission Requests: When the App requests device permissions (notifications, camera for profile photos), we explain why we need access through clear, user-friendly messages.

10. Third-Party Links

The App may contain links to external websites or services (such as crisis support resources). We are not responsible for the privacy practices of third parties. We encourage you to review their privacy policies before providing personal information.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or new features. We will:

• Notify you of material changes via email or in-app notification at least 30 days in advance
  
• Post the updated policy with a new "Last Updated" date
  
• For material changes affecting GDPR rights, obtain your consent where required
  
• Maintain a version history at kinspace.co/privacy-history
  

Your continued use of the App after changes become effective constitutes acceptance of the updated policy, unless the changes require your explicit consent under applicable law.

12. Human Rights Commitment

KINSPACE is committed to upholding human rights principles as outlined by the United Nations Office of the High Commissioner for Human Rights (OHCHR). We:

• Respect the right to privacy as a fundamental human right
  
• Ensure transparency in our data practices
  
• Provide meaningful control over personal information
  
• Protect against discrimination in our AI systems through regular fairness testing
  
• Design technology that respects human dignity and autonomy
  
• Ensure our AI coaching augments human decision-making rather than replacing it
  
• Maintain accountability for our data practices through regular audits and transparency reports
  
• Ensure our services are accessible to users with diverse abilities and needs
  
• Respect cultural differences in communication styles and workplace norms
  

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information:

KINSPACE Pty Ltd
Email: connect@kinspace.co
Support: connect@kinspace.co
Website: https://kinspace.co
Address: 521/6 Sedgeland Drive, Sunshine Coast, QLD 4567, Australia
ABN: 98 571 677 108

Privacy Contact: Sara Liyanage-Denney, Founder & CEO

Data Protection Officer: Not required under current regulations

Response Time: We aim to respond to all privacy enquiries within 5 business days and resolve requests within 30 days.

14. Important Disclaimers

14.1 Not a Mental Health or Therapy Service

⚠️ IMPORTANT: The Outlet is designed to help with professional workplace communication coaching and is NOT a substitute for mental health services, therapy, counselling, or psychiatric care. We are not therapists, psychiatrists, psychologists, counsellors, or mental health professionals.

When to Seek Professional Help:

• If you are experiencing anxiety, depression, or other mental health symptoms
  
• If you are having thoughts of self-harm or suicide
  
• If you are in crisis or experiencing a mental health emergency
  
• If your workplace stress is significantly impacting your wellbeing
  
• If you have been diagnosed with a mental health condition
  

Crisis Resources:

• Australia: Lifeline 13 11 14 (24/7) | Beyond Blue 1300 22 4636 | MensLine Australia 1300 78 99 78
  
• New Zealand: Lifeline 0800 543 354 (24/7) | Suicide Crisis Helpline 0508 828 865
  
• UK: Samaritans 116 123 (24/7)
  
• US: 988 Suicide and Crisis Lifeline
  
• International: Contact your local emergency services or crisis helpline
  

The Outlet's AI coaching is designed to help you communicate better in specific conversations—it is not designed to diagnose, treat, or manage mental health conditions.

14.2 Not Legal, HR, or Professional Advice

The Outlet provides communication coaching only and does NOT provide:

• Legal advice (consult a lawyer for legal issues)
  
• HR guidance (contact your HR department for HR matters)
  
• Workplace mediation services
  
• Organisational consulting
  
• Conflict resolution services beyond communication coaching
  
• Advice about discrimination, harassment, or bullying
  

For workplace disputes, discrimination, or harassment issues, please contact:

• Your HR department or Employee Assistance Programme (EAP)
  
• An employment lawyer
  
• Your local Fair Work Commission (Australia) or equivalent labour authority
  
• Safe Work Australia (for workplace safety issues)
  

14.3 Our AI Coaches Are Not Medical or Psychological Professionals

The AI coaches in The Outlet:

• Are not licensed therapists, counsellors, or mental health professionals
  
• Cannot diagnose conditions or prescribe treatment
  
• Do not provide medical or psychological advice
  
• Have no access to your medical or psychiatric history
  
• Cannot provide crisis intervention
  
• Are designed to offer communication coaching only
  

14.4 AI Limitations

Our AI coaching:

• Is based on general communication principles, not personalised psychological assessment
  
• May not be appropriate for all situations or individuals
  
• Does not have access to the full context of your workplace, relationships, or personal circumstances
  
• Cannot understand complex organisational dynamics or power imbalances
  
• Should not be relied upon as your only source of guidance
  
• May provide suggestions that don't work for your specific situation
  
• Does not replace professional advice from qualified experts
  

Always use your own judgement and consider seeking professional advice for serious workplace issues, mental health concerns, or situations involving abuse, discrimination, or harassment.

14.5 Your Responsibility

By using The Outlet, you acknowledge that:

• You understand this is a coaching tool, not therapy or professional advice
  
• You take full responsibility for any decisions you make based on our guidance
  
• You will seek appropriate professional help if needed
  
• You will not rely solely on The Outlet for important decisions affecting your wellbeing or career
  
• You understand the limitations of AI coaching
  
• You will use The Outlet in conjunction with, not as a replacement for, your own judgement and professional resources
  

15. Apple App Store Requirements

This Privacy Policy complies with Apple's App Store Review Guidelines and App Tracking Transparency framework:

Data Collection Transparency: All data collection is disclosed in this policy and in our App Store privacy nutrition label

User Consent: We obtain explicit consent before collecting data not necessary for core functionality
App Tracking Transparency (ATT): We do not track you across apps and websites owned by other companies for advertising or advertising measurement purposes

Data Minimisation: We collect only data necessary to provide our services

Third-Party SDKs: All third-party code follows the same privacy standards outlined in this policy
Account Deletion: Users can delete their accounts and data directly within the App (Settings → Account → Delete Account)

Purpose Strings: When the App requests access to device features, we provide clear explanations of why we need that access

16. California Privacy Rights (CCPA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act:

• Right to know what personal information is collected
  
• Right to know if personal information is sold or shared (and to whom)
  
• Right to opt-out of sale of personal information
  
• Right to deletion of personal information
  
• Right to non-discrimination for exercising your privacy rights
  

We do not sell personal information. We do not share personal information for cross-context behavioural advertising.

To exercise your CCPA rights, contact connect@kinspace.co or use the in-app data rights features.

17. Updates and Version History

This Privacy Policy was last reviewed and approved by KINSPACE leadership on October 1, 2025.
We maintain a version history of this Privacy Policy to help you track changes over time.

Current Version: 1.0

Consent

By creating an account and using The Outlet, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein, where consent is the legal basis for processing.

Last Updated: October 1, 2025
Effective: October 1, 2025
Version: 1.0