Ian Shivers trading as Bondi Behaviourist — ABN 29 775 879 915

Collaroy NSW 2097 — [email protected] — 0457 187 206

Effective date: Sept 2026 Version 2.0  Privacy Policy: bondibehaviourist.com/privacy-policy

SECTION A — PRIVACY POLICY

1. Who we are and what this Policy covers

1.1      Bondi Behaviourist is operated by Ian Shivers as a sole trader (ABN 29 775 879 915). It is a solo practice: Ian Shivers is the only person who handles your personal information on our behalf.

1.2      This Policy explains how we collect, use, store and disclose personal information when you enquire about, book or use our Services — dog training and behaviour consultations, programs, group classes, workshops, Shadow Experiences, our website, our newsletter and TRACE, our AI dog behaviour tool.

1.3      Canine Caregivers membership is provided by Canine Caregivers Pty Ltd (ABN 39 670 538 655), a separate business. Its handling of your information is covered by the Canine Caregivers Privacy Policy at caninecaregivers.com.au. This Policy explains what we share with Canine Caregivers and why (clause 6.5).

1.4      As a small business we are not currently required by the Privacy Act 1988 (Cth) to comply with the Australian Privacy Principles, but we choose to handle your personal information in accordance with them. Where we refer to "personal information" we mean information about an identified or reasonably identifiable individual.

3.1      Directly from you: through enquiry and booking forms, the questionnaire, phone, SMS, email, the private support channel, video calls, in-person sessions, TRACE conversations and account sign-up.

3.2      From our providers: Stripe (payment status), GoHighLevel (form submissions, bookings, email engagement), Delphi (TRACE account and conversation data, and tier and usage data passed to GoHighLevel by webhook).

3.3      From Canine Caregivers, where you joined a Bondi Behaviourist Service through Canine Caregivers or your Canine Caregivers membership includes TRACE: your name, email address and membership status, so we can provision access.

3.4      From others: your vet, with your consent, where health information is relevant; a family member who books on your behalf.

4. Why we collect and use it

4.1      To deliver Services: assess your dog, plan and deliver sessions, provide written plans and recordings, run the support channel, provision TRACE and membership access, and communicate about bookings.

4.2      To keep people and animals safe: to know about bite history, council declarations and health conditions before we meet your dog.

4.3      To take payment, issue invoices and receipts, and recover unpaid amounts.

4.4      To operate TRACE: to generate answers, monitor for safety concerns and misuse, provide support and manage your account and tier. Clause 7 sets out how conversations are used in detail.

4.5      To improve our Services and TRACE, using de-identified information wherever possible (clause 7.3).

4.6      To send service messages (booking confirmations, receipts, account notices, changes to terms) and, only if you have opted in, our newsletter and marketing (clause 8).

4.7      To meet legal obligations, resolve disputes and enforce our terms.

4.8      For educational or promotional content from recorded sessions, only with the specific consents described in clause 9. TRACE conversations are never used for this purpose.

5. Cookies and analytics

5.1      Our website uses cookies and Google Tag Manager for analytics and to make the site work. You can control cookies in your browser; some features may not work without them. Our booking widgets and review widgets are provided by GoHighLevel and set their own cookies.

6.1      We disclose personal information only to the providers we use to run the business, and otherwise only where you have agreed or the law requires. We do not sell personal information.

6.2      Overseas disclosure. Stripe, GoHighLevel, Delphi and Google store or process information outside Australia, principally in the United States. By using TRACE you consent to your conversation content being processed by Delphi in the United States, where privacy law differs from Australian law. We choose providers with published privacy commitments and security certifications, and we limit what we send them to what is needed.

6.3      We may also disclose information where required by law, a court order or a regulator, or to protect someone's safety — for example, reporting a dangerous dog incident to a council where we are obliged to.

6.4      Partners. We may receive a commission if you purchase from Petsy Pet Insurance or Lyka Pet Food through links on our site. We do not share your information with them and they do not share yours with us. If you follow a partner link, the partner's privacy policy applies from that point.

6.5      Canine Caregivers. Where your purchase (for example the Complete Care Program, or an annual or lifetime TRACE Membership) includes Canine Caregivers membership, we give Canine Caregivers your name, email address and what you are entitled to, so it can set up your membership. Canine Caregivers becomes responsible for that information under its own policy. Where a Canine Caregivers membership includes TRACE, Canine Caregivers gives us the same details in reverse so we can provision TRACE.

7. TRACE conversations

7.1      What happens when you use TRACE. Your messages are sent to Delphi, which generates a reply using an AI model trained on Ian Shivers' material. Delphi stores the conversation on its platform. Your account details and tier are synchronised to our GoHighLevel system so we can manage your access and send account emails.

7.2      Who can read your conversations. Ian Shivers can access and read conversations through the Delphi dashboard. He does this to check that TRACE is answering safely and accurately, to respond if a conversation indicates a safety risk to a person or animal, to help you if you ask for support, and to investigate misuse. No one else at Bondi Behaviourist has access. Delphi's staff may access data under Delphi's own policy.

7.3      Improving TRACE. We review conversations to find questions TRACE answers poorly and to improve its knowledge base. Before any conversation content is used for that purpose, Ian Shivers personally reviews it and removes your name, contact details, suburb and location, your dog's name, and any distinctive detail about you, your household or an incident that could identify you. What is kept is the information about the dog's behaviour, the question asked and the answer given. We do not use a conversation where the dog-related content alone would make you identifiable. De-identified content may be added to TRACE's knowledge base and used to test its answers.

7.4      We do not quote your conversations. Your conversations are never quoted, excerpted or reproduced in TRACE training material, courses, webinars, posts or any other material. The only use beyond operating TRACE is the de-identified improvement described in clause 7.3.

7.5      Delphi's own use. Delphi may use conversation data for its own purposes, including improving its platform and models, as described in Delphi's Privacy Policy at delphi.ai/privacy. This is not something we control or can switch off. If you are not comfortable with Delphi's policy, do not use TRACE.

7.6      What not to enter. Do not enter other people's personal information unless you are authorised to, and do not enter sensitive information about people that is not needed for your question. TRACE is not an emergency service; if a person or animal is at immediate risk, seek help in person.

7.7      Retention and deletion. Conversations are retained on the Delphi platform for the period set by Delphi's policy. We can delete your conversations from TRACE at any time on request (clause 11). We cannot export your conversations in bulk; if you ask for a copy we will provide it manually.

9. Recordings, photos and educational content

9.1      We record a session only with your written consent given before the session. Complete Care clients receive recordings of their own sessions as part of the Program.

9.2      We ask for separate consent before using any recording, photo or excerpt: (a) for educational purposes, such as a course, webinar, Canine Caregivers content or TRACE material; and (b) for promotional purposes, such as our website or social media. You can give one consent without the other, and refuse both without affecting your Service.

9.3      You can withdraw consent at any time by email. We stop new uses and remove the content from places we control within a reasonable time; we cannot recall content already published elsewhere.

9.4      Recordings are stored in Google Drive with access limited to Ian Shivers, and to Dominique Hone of Canine Caregivers only for content you have consented to share there.

9.5      In group classes we tell participants before any recording or photography, and we do not publish an identifiable person or dog without that person's consent.

10.1    Your information is stored in the systems of the providers in clause 6 and in our own devices and cloud storage, protected by passwords, two-factor authentication where available, and device encryption. We limit access to Ian Shivers.

10.2    We keep client records, plans and notes for 7 years after your last Service, which is the period we need to meet tax and legal obligations and to deal with any dispute or claim. We keep session recordings for 2 years, or for as long as the content is in use where you have consented to educational or promotional use. TRACE conversations are retained as set out in clause 7.7. Newsletter data is kept until you unsubscribe and then suppressed so we do not email you again.

10.3    When information is no longer needed we delete it or de-identify it. Deletion from provider systems follows each provider's own retention practices.

10.4    Data breaches. If we become aware of a breach that is likely to cause serious harm, we will notify affected people and, where required, the Office of the Australian Information Commissioner, as soon as practicable.

11.1    You may ask to see the personal information we hold about you, to correct it, or to have it deleted, by emailing [email protected]. We respond within 30 days. We may need to verify your identity first.

11.2    We may keep information we are legally required to keep, or need to keep for a dispute or claim, and will tell you if that is the case.

11.3    You can withdraw a consent you have given — to marketing, to recording, or to educational or promotional use of a recording — at any time. Withdrawal does not affect anything done before it.

12.1    If you are concerned about how we have handled your information, email [email protected]. We will acknowledge your complaint within two business days and aim to resolve it within 30 days.

12.2    If you are not satisfied, you may complain to the Office of the Australian Information Commissioner at oaic.gov.au or 1300 363 992.

13.1    We may update this Policy. The current version is always at bondibehaviourist.com/privacy-policy with its effective date. For material changes affecting current Clients or TRACE users we will email you before they take effect.