Privacy Policy

Version date: 28th September 2026

1. ABOUT THIS POLICY

1.1 This Privacy Policy explains how BASC Enterprises Pty Ltd (ABN 22 636 407 166) trading as Human Performance Collaborative ("Huperco", "we", "us", "our") collects, holds, uses and discloses personal information in connection with Flying Fit. It applies to Flying Fit only.

1.2 This Policy should be read alongside the Flying Fit Terms and Conditions ("Terms"). Capitalised terms used here (such as Clearance, Consent Holder, Eligible Pilot, Eligible Family Member, Platform, Program and Tier) have the meaning given in the Terms.

1.3 Flying Fit Programs are delivered through Lumin, a third-party platform. Lumin's own terms of use and privacy policy also apply to your use of the Platform.

2. WHAT PERSONAL INFORMATION WE COLLECT

2.1 We collect the following personal information as you register for and take part in Flying Fit:

Registration and eligibility

• Your name, email address and the Program you select.

• For Eligible Pilots: your AIPA membership details, including your AIPA member number, so AIPA can confirm your eligibility.

• For Eligible Family Members, including minors: your relationship to the Eligible Pilot, and the Eligible Pilot's name and AIPA member number, so AIPA can confirm the Eligible Pilot's membership and we can apply any family discount.

Payment

• Payment for Momentum is processed by Stripe or PayPal through our Squarespace checkout. Elevate is invoiced through Xero. We receive confirmation of payment and transaction details. Full card details are handled by the payment provider and are not held by us.

Exercise Clearance

• Your DAME or GP exercise clearance, or Parental Clearance, which you provide by email. See clause 3 for how we treat this document.

Your Lumin profile

• Once your Clearance and eligibility are verified, we create a profile for you on Lumin. Your Clearance status (current, and its expiry date) is attached to this profile. The Clearance document itself stays off the Platform.

Lifestyle Onboarding Quiz

• If you choose to complete our optional Lifestyle Onboarding Quiz within Lumin, we collect your responses to generate a personalised report. The report is generated automatically from your responses and reviewed by our team before we send it to you through the Platform's chat function.

Fitness performance and body composition data

• Depending on your Program, you may choose to provide fitness performance data (such as repetitions, times, or fitness and flexibility test results) or body composition data (limited to BMI and hip:waist ratio). Providing this information is optional - see clause 14.2 of the Terms.

Communications and content you share

• Messages you send us directly or through the Platform's chat function, exercise comments you leave within your Program sessions, and feedback you choose to provide. Exercise comments are for questions about your Program; health or medical questions are best taken to your DAME or GP.

• For Elevate and Momentum Youth only: images or video you choose to share with your coach for technique review. For Momentum Youth, these are shared in the group chat, where the Consent Holder can see them (see clause 10). We do not request images or video from Foundations or Momentum participants.

Minors (14–17 years)

• For an Eligible Family Member under 18: their name and email address, optionally their date of birth, and the Parental Clearance.

• For the Consent Holder: their name, email address and relationship to the minor, and their annual reconfirmation of consent. See clause 10.

3. HEALTH INFORMATION AND YOUR CONSENT

3.1 Some information we collect is "health information" under the Privacy Act, which treats it as sensitive information. For Flying Fit this includes your Clearance document, any body composition data you provide, and some Lifestyle Onboarding Quiz responses (for example, about sleep, smoking, alcohol, or stress).

3.2 We collect this information only with your consent, and only where it is reasonably necessary to deliver Flying Fit. You give that consent when you provide the information to us. Apart from your Clearance, which is a condition of access under clause 5 of the Terms, providing this information is optional.

3.3 Our role is administrative. We keep your Clearance document as a record that a Clearance existed and was current at the relevant time. We read it only to confirm it is current and relates to you, and we leave its clinical content with the practitioner who issued it. We do not request blood test results, cardiac test results, blood pressure, cholesterol, or other clinical diagnostic information - see clause 10 of the Terms.

3.4 If you send us information we have not asked for - for example, a full medical report attached alongside your Clearance, or health details in a chat message or exercise comment - we will destroy or de-identify the parts we do not need, as soon as practicable and where lawful to do so.

4. HOW WE COLLECT YOUR INFORMATION

4.1 We collect most information directly from you: through our Squarespace checkout, by email, and through the Platform.

4.2 We also collect some information from others, where it is unreasonable or impracticable to collect it from you directly:

• AIPA confirms to us whether an Eligible Pilot is a current AIPA member, for every registration, including registrations by Eligible Family Members and minors;

• an Eligible Pilot may give us the name and contact details of an Eligible Family Member they nominate; and

• a Consent Holder provides information about the minor they consent for.

5. DEALING WITH US ANONYMOUSLY

5.1 You are welcome to ask us general questions about Flying Fit without identifying yourself. To register for and take part in a Program, we need to identify you, so we can confirm your eligibility and Clearance.

6. HOW WE USE YOUR INFORMATION

6.1 We use your personal information to:

• verify your eligibility and Clearance, and administer your access to Flying Fit;

• create and manage your Lumin profile and deliver your Program;

• generate your Lifestyle Onboarding Quiz report, if you complete the quiz;

• communicate with you about your Program, including Clearance renewal reminders and through the Platform's chat and exercise comment functions;

• process payments and apply any family discount;

• respond to your enquiries and complaints; and

• improve Flying Fit, including through any feedback you choose to provide — see clause 14.5 of the Terms.

6.2 We use your information for these purposes, for directly related purposes you would reasonably expect, with your consent, or where required or authorised by law.

7. HOW WE DISCLOSE YOUR INFORMATION

7.1 We disclose personal information to the following parties, for the purposes described:

• Lumin Sports Technology Pty Limited: to host your Lumin profile and deliver your Program.

• Squarespace, Stripe and PayPal: to process your registration and payment.

• Xero - to issue and manage Elevate invoices.

• Google (Google Workspace): our email and document storage provider, where Clearance documents and correspondence are received and held.

• AIPA: to confirm eligibility for every registration, in every Tier, we give AIPA's membership team the Eligible Pilot's name and AIPA member number and ask them to confirm the Eligible Pilot's current membership. Where you are an Eligible Family Member, including a minor, we give AIPA only the Eligible Pilot's details - your own name is not shared. AIPA will therefore know that a registration has been made in connection with the Eligible Pilot's membership. Separately, we may give AIPA de-identified, aggregate usage data (for example, total participation numbers) in a form and at a scale where you cannot reasonably be identified. Your Clearance, quiz responses, fitness data and Program details stay with us and are never shared with AIPA - see clause 14.4 of the Terms.

• Our professional advisers and insurers - where reasonably necessary, for example to obtain legal advice or manage a claim.

7.2 We do not sell your personal information. We disclose it only as described in this Policy, with your consent, or where required or authorised by law.

8. WHERE YOUR INFORMATION IS STORED

8.1 Lumin stores Platform data, including your Lumin profile, Program information, chat messages and exercise comments, in Sydney, Australia.

8.2 Some of our other service providers store or process information outside Australia:

• Squarespace, Inc. - United States;

• Stripe - Australia and the United States;

• PayPal - Australia, the United States and other countries where PayPal operates;

• Xero - United States; and

• Google - the United States and other countries where Google operates data centres.

8.3 We choose established providers with published privacy and security commitments, and take reasonable steps to ensure they handle your information consistently with the APPs.

9. NEWSLETTERS AND UPDATES

9.1 We may send you Flying Fit newsletters and updates about Programs, partner offers, and new Tiers. Every such email includes an unsubscribe link, and you can also opt out at any time by contacting us. Opting out leaves your Program communications (such as Clearance reminders and coach messages) unaffected.

9.2 We do not use Lifestyle Onboarding Quiz responses, fitness data, or Clearance information for marketing.

10. MINORS

10.1 Flying Fit is available from 14 years of age. A minor's participation requires a Parental Clearance from a Consent Holder, reconfirmed annually — see clause 6 of the Terms.

10.2 We communicate with a minor only through a group chat on the Platform comprising the minor, the Consent Holder and the minor's coach, including our responses to any exercise comments the minor leaves. The Consent Holder can therefore see all Program communication from us to the minor.

10.3 A minor's date of birth is optional, and is deleted when their account is archived.

10.4 Any images or video a minor shares with their coach are shared in the group chat described in clause 10.2.

10.5 A Consent Holder may make an access, correction or deletion request on a minor's behalf under clause 13.

11. STORAGE AND SECURITY

11.1 Your Lumin profile, including your Clearance status, Program details, chat messages, exercise comments, and any quiz responses or fitness data you provide, is stored on the Platform in Sydney, Australia.

11.2 Your registration and payment details are held by Squarespace, Stripe or PayPal, and (for Elevate) Xero, and in our own business records.

11.3 Clearance documents are received by email at flyingfit@huperco.com.au, saved to an access-restricted folder in our Google Workspace account, and the original email is then deleted. Clearance documents are never uploaded to the Platform.

11.4 We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and unauthorised access, modification or disclosure, including limiting access to personal information to those who need it and requiring two-factor authentication on accounts that can access it. No method of storage or transmission is completely secure.

11.5 If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required under the Notifiable Data Breaches scheme.

12. HOW LONG WE KEEP YOUR INFORMATION

Information

Retention

Lumin profile, including quiz responses, fitness and body composition data, chat history and exercise comments

Approximately 90 days after your last Program session, then archived. Archived data is deleted from Lumin only on a hard-delete request from Huperco.

Minor's group chat history, including any images or video shared in it

Decision pending: whether Huperco requests hard deletion from Lumin at Program expiry.

Minor's date of birth

Deleted when the minor's account is archived

Clearance documents (adults)

5 years from the end of your last Program

Clearance documents and consent records (minors)

5 years, or longer if advised

Financial and transaction records

7 years to meet our tax and corporate record-keeping obligations

12.1 When we no longer need personal information for any purpose described in this Policy, or to meet a legal obligation, we take reasonable steps to destroy or de-identify it.

13. ACCESS AND CORRECTION

13.1 You may ask us for access to the personal information we hold about you, or ask us to correct information that is inaccurate, out of date, incomplete or misleading, by contacting us using the details in clause 16. We will respond within 30 days, and there is no charge to make a request.

13.2 If we decline a request, we will tell you why in writing and explain how to complain.

13.3 Because much of your Program information is held on Lumin, we will liaise with Lumin on your behalf to action your request. You may also contact Lumin directly.

14. COOKIES

14.1 Our website uses strictly necessary cookies only, for core functions such as checkout and site security. Non-essential cookies, including tracking and advertising cookies, are switched off. Strictly necessary cookies may involve Squarespace processing information in the United States, as described in clause 8.

15. COMPLAINTS

15.1 If you have a concern about how we have handled your personal information, please contact us using the details in clause 16. We will acknowledge your complaint promptly and aim to resolve it within 30 days.

15.2 If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or on 1300 363 992.

16. CONTACT AND CHANGES TO THIS POLICY

BASC Enterprises Pty Ltd trading as Human Performance Collaborative (Huperco)

Attention: Privacy Officer, Brendyn Appleby, Director

Email: info@huperco.com.au

16.1 We may update this Policy from time to time. The version date at the top shows when it was last updated, and the current version is always available at www.huperco.com.au/privacy