FREEDOM ACADEMY

PRIVACY POLICY

Our commitment to protecting your privacy

This privacy policy applies to the collection, storage, use and disclosure of personal information by or on behalf of Hibiki Pty Ltd (ABN 40 675 402 203), trading as Freedom Academy (referred to in this policy as “our”, “we” or “us”). Please read it carefully.

We are committed to protecting your personal information, and ensuring its privacy, accuracy and security. We handle your personal information in a responsible manner in accordance with the Privacy Act 1988 (Act) and the Australian Privacy Principles (APPs).

By giving us your personal information when you contact us, apply for or use any of our programmes, or visit our website (www.freedomacademy.com.au), you agree to your information being collected, stored, used and disclosed as set out in this Privacy Policy.

Personal information

‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether or not recorded in a material form.

‘Sensitive information’ (a type of personal information) means information or an opinion about an individual’s race or ethnic origins, political opinions and associations, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, trade or professional associations and memberships, union membership, criminal record, health or genetic information or biometric information.

Whose personal information do we collect?

We may collect your personal information from a range of sources, including from you, contractors, and our business partners. For example, we may collect your personal information when you apply for one of our programmes (Freedom Accelerator, Freedom Launchpad, or ScaleUp CEO), acquire a product or service from us, provide a service or product to us, apply for employment with us, or communicate with us via our website, by email, telephone, or in writing.

Wherever reasonable and practicable, we collect personal information from the individual to whom the information relates. If you provide personal information about someone other than yourself, you agree that you have that person’s consent to provide the information for the purpose for which you provide it to us, and that you have told them about this Privacy Policy and where to find it.

What types of personal information do we collect and hold?

The personal information we may collect includes:

  • name and contact details, including address, phone number, and email;
  • information provided as part of an application to any Freedom Academy programme, including your current employment or business situation, career or business goals, and relevant background;
  • for Freedom Accelerator applicants specifically, information relevant to assessing placement suitability, which may be shared with approved partner businesses as part of the placement process;
  • bank account or credit card details and associated information, as reasonably required to process payments at your request; and
  • any other information you provide to us during coaching sessions, community participation, or ongoing programme support.

We will only collect your sensitive information if you have consented to us doing so, for example, as part of information you choose to share during coaching or an application assessment.

How do we collect personal information?

We only collect personal information by lawful and fair means. We usually collect personal information from:

  • application forms, whether for Freedom Accelerator, Freedom Launchpad, or ScaleUp CEO;
  • face-to-face meetings, calls, and application interviews;
  • electronic communications, including emails and attachments such as CVs;
  • our website, including if you use it to contact us, join our mailing list, engage in our community, give us feedback, or enquire about a programme;
  • various technologies such as cookies, pixels, and web beacons, and navigational data collection such as log files and clickstream data; and
  • analytical web tools such as Google Analytics, and social platforms including Facebook, Instagram, and LinkedIn, to help us understand and improve our services and to deliver targeted advertising.

Why do we collect personal information?

We collect personal information that is necessary for us to:

  • assess your application and suitability for a Freedom Academy programme;
  • provide you with the programme, coaching, or placement services you have requested;
  • for Freedom Accelerator specifically, facilitate introductions and placement with approved partner businesses;
  • provide you with information about programmes, content, or services that may be of interest to you;
  • improve the programmes and services we provide; and
  • carry out our functions and activities, including meeting our legal and regulatory obligations.

If you do not provide your personal information, we may not be able to assess your application, supply the requested programme, employ you, or otherwise deal with you.

How do we deal with unsolicited personal information?

If we receive personal information about you that we have not requested, and we determine that we could not have lawfully collected that information under the APPs had we asked for it, we will destroy or de-identify the information if it is lawful and reasonable to do so.

Do you have to disclose your identity when dealing with us?

Where lawful and practicable, we will give you the option of interacting with us anonymously or using a pseudonym. Note that our application and placement processes generally require identification in order to assess suitability and, for Accelerator applicants, to facilitate placement with a partner business.

Use of personal information

We only use your personal information for the purpose for which it was provided to us, for related purposes, or as required or permitted by law. Such purposes include:

  • assessing programme applications and administering enrolment across Freedom Accelerator, Freedom Launchpad, and ScaleUp CEO;
  • for Freedom Accelerator, facilitating and supporting your placement with an approved partner business, and supporting the ongoing coaching relationship following placement;
  • responding to your enquiries and feedback;
  • market research and programme development, so that we can improve our offerings;
  • general administration, reporting, and management, including invoicing, payment processing, risk management, and quality assurance;
  • employment-related purposes, such as recruiting and providing services to our staff and coaching team; and
  • other purposes related to our functions and activities, including meeting our legal and contractual obligations.

Disclosure of personal information

We may disclose, and you consent to us disclosing, your personal information to third parties:

  • engaged by us to provide products or services or undertake functions on our behalf, such as IT systems, payment processing, and database management;
  • that are authorised by you to receive information we hold;
  • for Freedom Accelerator applicants and graduates specifically, approved partner businesses within our placement network, to the extent reasonably necessary to assess and facilitate placement;
  • that are our business partners, joint venturers, or agents such as external advisers, where reasonably required to obtain advice, prepare legal proceedings, or investigate suspected unlawful activity or serious misconduct; or
  • as required or permitted by law.

Marketing use and disclosure

We may use and disclose your personal information (other than sensitive information) to provide you with information about our programmes, podcast, or content that we consider may be of interest to you. You may opt out at any time by contacting us via email or in writing at the details below, or by clicking “unsubscribe” where applicable.

Use or disclosure of sensitive information

We will only use or disclose your sensitive information for the purpose for which it was initially collected or for a directly related purpose, as required or permitted by law, or where you consent to the use or disclosure.

How is my personal information kept secure?

We take reasonable steps to protect your personal information from misuse, interference, loss, and unauthorised access, modification, and disclosure. Such steps include physical and electronic data security measures, computer and network security including firewalls and password access, restricting access on a need-to-know basis, retaining personal information no longer than reasonably required, and entering into confidentiality agreements with staff, coaches, and third parties, including partner businesses in our placement network.

Where we no longer require your personal information, including where we are no longer required by law to keep records relating to you, we will ensure it is de-identified or destroyed.

Data quality

We take reasonable steps to ensure your personal information is accurate, complete, and up to date. We rely on you to advise us of any changes or corrections. If you consider that the information we hold about you is not accurate, complete, or current, please let us know as soon as possible.

Access

You may request access to the personal information we hold about you by contacting us. We will respond within a reasonable time, and provide access unless otherwise permitted or required by law. If we deny access, we will notify you of the basis for the denial unless an exception applies. No fee applies for requesting access, though we reserve the right to charge a reasonable fee where we do provide it.

Correction

If you believe personal information we hold about you is incorrect, incomplete, or not current, you may request that we update or correct it. We will deal with your request within a reasonable time. If we do not agree with the requested correction, we will give you written notice setting out our reasons.

Identifiers

We do not adopt, use, or disclose government related identifiers except as required or permitted by law.

Complaints

If you have a complaint about the collection, storage, use, or disclosure of your personal information, please contact our Privacy Officer using the details below, along with details of your complaint and any supporting evidence. Our Privacy Officer will review and respond to all complaints. If you are not satisfied with our response, you may raise your concerns with the Australian Information Commissioner via www.oaic.gov.au.

Changes to this Privacy Policy

We reserve the right to revise this Privacy Policy or any part of it from time to time. Please review this policy periodically for changes. Any revised policy will be placed on our website at www.freedomacademy.com.au/privacy-policy. Your continued use of our website, application to or participation in our programmes, or provision of further personal information after this policy has been revised, constitutes acceptance of the revised policy.

How to contact us

If you have any questions about this Privacy Policy, please contact Freedom Academy:

  • (a) by email to hello@freedomacademy.com.au  with subject line “Attn: Privacy Officer”
  • (b) by writing to: Privacy Officer, Freedom Academy, The Hub, Level 1 Suite 1101, 31A Lasso Road Gregory Hills NSW 2557

Effective date: 15.07.2026