Privacy Policy

Branwell Pty Ltd (ABN 38 642 130 676) trading as Soul 2 Path
Last updated: 1 May 2025

1. Our commitment to your privacy

Branwell Pty Ltd trading as Soul 2 Path (“Soul 2 Path”, “we”, “our”, “us”) respects your right to privacy and is committed to safeguarding the Personal Information¹ we hold. We comply with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), the Spam Act 2003 (Cth) and, where relevant, the Telecommunications (Interception and Access) Act 1979 (Cth) and other applicable Australian laws.

2. What Personal Information we collect

Category	Examples
Identity	full name, preferred name, date of birth, gender
Contact	postal address, email address, telephone number, social‑media usernames
Transactional	records of sessions, invoices, payment method (but not card numbers)
Technical	IP address, device identifiers, browser type, cookies, usage statistics
Preference	appointment choices, communication preferences, feedback
Sensitive / Health²	spiritual or religious beliefs, health or disability information disclosed during sessions

¹ Personal Information has the meaning given in s 6(1) of the Privacy Act.
² We collect Sensitive Information only with your consent or where another APP exception applies (APP 3.4).

3. How we collect your information

directly from you (phone calls, online bookings, email, live chat, SMS)
automatically when you use our website or mobile services (cookies, analytics tags)
from publicly available sources (e.g. social‑media profiles) where you have made the information public
from third parties you authorise (e.g. payment processors or referral partners)

4. Why we collect, hold, use and disclose your information

to provide and administer psychic readings and related services
to verify your identity and process payments
to operate, protect, improve and personalise our website, apps and services
to send administrative messages, service updates and appointment reminders
to market our products and services (you may opt out at any time—see section 8)
to comply with legal obligations, resolve disputes and enforce agreements
for quality assurance, training and security monitoring (e.g. call recordings)

We do not sell or rent Personal Information.

5. Disclosure to third parties

We may disclose Personal Information to:

payment providers (e.g. Westpac, Qvalent PayWay, PayPal)
IT and cloud‑hosting suppliers
professional advisers (lawyers, accountants, auditors)
regulators, law‑enforcement agencies or courts where required or authorised by law
contractors who assist us in delivering services (e.g. SMS gateway, email service)

All third‑party service providers are bound by confidentiality and privacy obligations.

6. Overseas disclosure

Some third‑party providers are located outside Australia (e.g. data centres in the United States or the European Union). Before disclosing Personal Information overseas we take reasonable steps to ensure the recipient either:

is subject to a law or binding scheme substantially similar to the APPs; or
contractually agrees to protect the information in line with the APPs.

7. Storage and security

We store Personal Information in secure electronic systems (with multi‑factor authentication, encryption in transit and at rest) and, where necessary, in locked physical files. We implement industry‑standard safeguards and review them regularly to prevent misuse, interference, loss, and unauthorised access, modification or disclosure (APP 11).

8. Direct marketing and cookies

We may send you promotional communications about Soul 2 Path via email, SMS or social media. You can opt out at any time by following the unsubscribe instructions or contacting us (section 13).

Our website uses cookies and similar technologies to remember your preferences and gather analytic data. You can disable cookies in your browser, but some features may not work.

9. Access and correction (APP 12 & 13)

You may request access to, or correction of, the Personal Information we hold about you by contacting us (section 13). We will respond within a reasonable period (usually 30 days). If we refuse access or correction, we will provide written reasons and information on how you may complain.

10. Data retention and de‑identification

We keep Personal Information only as long as needed for the purposes set out in this Policy or as required by law (e.g. taxation or health‑record retention laws). When no longer required, we securely destroy or de‑identify the information.

11. Notifiable Data Breaches

In the unlikely event of a data breach likely to result in serious harm, we will investigate promptly and, where required under Part IIIC of the Privacy Act, notify affected individuals and the Office of the Australian Information Commissioner (OAIC).

12. Anonymity and pseudonymity (APP 2)

Where lawful and practicable (e.g. general enquiries), you may interact with us anonymously or using a pseudonym. Full identity details may be required for paid services or where mandated by law.

13. How to make a privacy enquiry or complaint

If you have a question, concern or complaint about this Privacy Policy or the way we handle your Personal Information, please contact our Privacy Officer:

Privacy Officer
Branwell Pty Ltd t/a Soul 2 Path
U2 290 Boundary Street, Spring Hill, QLD., 4000
Email: [email protected]
Tel: 1300 815 508

We will acknowledge receipt within 7 days and aim to resolve the issue within 30 days. If you are not satisfied, you may complain to the OAIC (www.oaic.gov.au).

14. Changes to this Privacy Policy

We may update this Policy from time to time. The current version will be posted on our website and will apply from the “Last updated” date above. Material changes will be notified via email or prominent website notice.

Glossary

Personal Information – information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in material form or not.
Sensitive Information – a subset of Personal Information including information or opinion about an individual’s health, racial or ethnic origin, religious beliefs, sexual orientation, etc.
APPs – the Australian Privacy Principles in Schedule 1 of the Privacy Act 1988 (Cth).