PRIVACY POLICY
1. Who we are
Cuppa’s social network and social movement are operated by Cuppa of Life Pty Ltd, ABN 14 661 597 342. In this policy, “Cuppa”, “we”, “us” and “our” mean Cuppa of Life Pty Ltd.
This policy explains how Cuppa handles personal information for people joining its social network and social movement through its matched-conversation initiative. Cuppa brings good humans together through genuine connection. This policy describes our information-handling practices for that participation, including the protections against individual reporting to sponsors or employers below. Pick My Brain supplies and supports the technology used to operate the platform. For questions about Pick My Brain’s platform handling, you can also contact info@pickmybrain.world. Cuppa remains your contact for information Cuppa handles.
For privacy questions, access or correction requests, deletion requests or complaints, contact enquiry@cuppa.tv and address your message to the Privacy Officer.
2. Information we collect
We collect information needed to provide Cuppa’s matched-conversation service, arrange introductions, support participants and administer the service. Depending on how you use Cuppa’s matched-conversation service, this includes:
- Your name, email address and contact details you provide.
- Your age range, location, time zone, profile photograph, online profile links and information you choose to share about yourself, your interests and experiences.
- Your matching preferences, availability and preference for online or in-person conversations.
- Messages and booking information shared through the platform.
- Conversation completion records, ratings, reflections and feedback.
- Support enquiries, safety reports, complaints and information needed to investigate them.
- Payment, discount, receipt and refund records. Payments are processed through Stripe.
- Technical information about use of the website, such as device and browser information, pages visited and cookies used to support site functionality.
Cookies are small files stored by your browser. You can manage or delete cookies through your browser settings. Blocking cookies needed for sign-in or other essential functions may prevent parts of the service from working. This policy does not treat using the site as consent to optional advertising or marketing.
We collect information when you complete your profile, use the platform, arrange or record conversations, contact us or give feedback. We may also receive information about you from your match, for example a completion confirmation or a safety report, and from Pick My Brain and payment providers as needed to run the service.
You can ask general questions without giving your name. We need sufficient accurate information to create an account, provide matches, administer a payment or deal with a specific account request. If you do not provide information needed for those purposes, we may not be able to provide the relevant service.
Please do not include another person's private information in your profile or reflections unless you have an appropriate basis to share it. Avoid including sensitive details that are not needed for your participation. If we need to collect sensitive information, we will seek consent where required by law or rely on another lawful basis.
3. How we use information
We use personal information to:
- Create and manage accounts and participant profiles.
- Suggest and arrange matches using profile information and preferences, including AI-assisted matching.
- Provide introductions, messaging and booking functions.
- Record completed conversations and administer participation periods.
- Process payments, funded places and refunds.
- Send service messages, including joining information, match notifications, booking messages, reminders and important service changes.
- Provide support, investigate concerns and apply the Code of Conduct fairly.
- Understand feedback and improve Cuppa’s matched-conversation service and its matching process.
- Meet legal obligations and deal with disputes.
Cuppa does not use participant information to train general-purpose AI models or authorise its service providers to do so. AI-assisted matching is used to provide Cuppa’s matched-conversation service, not to create a general-purpose training dataset.
Matching suggestions are not a guarantee of compatibility, identity or safety. You remain free to decline a match or end a conversation. Contact enquiry@cuppa.tv if you have a concern about a match or information used in matching.
4. Who can see information
Your matches receive profile information and introduction information to help you decide whether and how to meet. Information you put in your profile card or send directly to a match is not private from that person. Booking details and calendar invitations may also disclose information needed to arrange the conversation, including contact details.
Cuppa and Pick My Brain staff involved in operating the service may access relevant profiles, preferences, reflections and support information. Safety concerns can be reviewed by Cuppa and Pick My Brain. We handle reports with care, but cannot promise absolute confidentiality: investigating a concern or protecting someone's safety may require relevant information to be shared.
We use service providers for platform operation, hosting, communications and payments. They may handle information needed to provide those services. Stripe processes payment information under its own privacy policy. If you follow an external link or use an independent video-meeting or other service to arrange your conversation, that service handles information under its own privacy policy. Read its privacy information before sharing details. This does not remove Cuppa’s obligations for information handled on its behalf.
We do not provide identifiable participant profiles, messages, reflections or individual participation reports to sponsors or employers. Any reporting to those organisations is limited to de-identified, combined information that does not identify individual participants. Funding your place does not give a sponsor or employer access to your personal participation information.
We may disclose relevant information where required or otherwise permitted by law, including to respond to a serious safety concern or a lawful request from an authority.
5. Marketing, photographs and participant stories
Service messages are different from optional marketing. We seek appropriate permission for optional newsletters and promotional communications, and you can unsubscribe or contact enquiry@cuppa.tv to change your choice. Necessary account, payment, safety and service messages may still be sent while you use Cuppa’s matched-conversation service.
Joining Cuppa does not give Cuppa permission to publish your photograph, testimonial, conversation or personal story. We seek separate permission for those uses. You can ask us to stop future use of material you previously agreed we could publish. We will explain what we can remove from channels we control and any limits on withdrawing material already distributed.
We may use de-identified, combined information to understand participation and describe the programme's impact. We take care not to identify people through small groups, distinctive details or combinations of information.
6. Overseas handling
Cuppa uses technology provided by Pick My Brain, which operates from Canada. Its published platform privacy policy describes hosting with Amazon Web Services in the United States and information handling by providers in Canada, the United States and Australia. For further information about Pick My Brain’s platform arrangements, contact info@pickmybrain.world or enquiry@cuppa.tv.
Personal information handled for Cuppa’s matched-conversation initiative may therefore be processed outside Australia or New Zealand. We take reasonable steps required by applicable privacy law in relation to overseas handling. Contact enquiry@cuppa.tv if you need more information about how a particular service provider handles your information.
7. Security and retention
We take reasonable steps to protect personal information we hold from misuse, loss and unauthorised access, modification or disclosure. No online service can guarantee absolute security. If a data breach occurs, we will assess it and notify affected people and regulators where required by applicable law.
We keep personal information for as long as reasonably needed to provide the service, handle enquiries or complaints, meet legal record-keeping obligations and resolve disputes. When information we hold is no longer needed, we take reasonable steps to delete or de-identify it, unless the law requires or permits retention.
The end of a participation round does not itself mean your account and all related records have been deleted. You can contact us to request account deletion or to ask what will be retained and why. We will coordinate platform requests with Pick My Brain.
Deleting an account cannot remove information another participant has already received or independently saved. We may need to retain some payment, complaint or legal records after an account closes.
8. Access, correction and deletion requests
You can ask us to access or correct personal information Cuppa holds about you. You can also ask us to delete information or close your Cuppa account. Contact enquiry@cuppa.tv with enough information for us to understand the request. We may need to verify your identity to protect your information.
We aim to respond to access and correction requests within 14 days and will comply with the period required by applicable law. Where New Zealand privacy law applies, the usual response period is no more than 20 working days, subject to lawful extensions notified to you. If we cannot provide access, make a requested correction or delete particular information, we will explain the reason where permitted and tell you how to raise a concern. We will coordinate with Pick My Brain where your request concerns information held in the platform.
You can withdraw permission for an optional use by contacting us. Withdrawal applies to future handling based on that permission and does not undo uses already lawfully made. We will explain if a requested change affects our ability to provide a particular part of the service.
9. Privacy complaints
If you have a privacy concern, email enquiry@cuppa.tv. We will investigate and explain the outcome. We aim to resolve complaints within 30 days. If more time is needed, we will let you know.
If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner at https://www.oaic.gov.au or the New Zealand Office of the Privacy Commissioner at https://www.privacy.org.nz, as applicable. This does not prevent you using another available complaint or legal process.
10. Changes to this policy
We will keep this policy current and explain material changes to how personal information is handled. A change to this policy does not itself give us permission for a new optional use that requires your consent.
Contact: enquiry@cuppa.tv
Cuppa of Life Pty Ltd
ABN 14 661 597 342