Privacy policy

Boomalex Pty Ltd, trading as Skilled Coaching ("we", "us", "our"), operates skilledcoaching.com and getemmaai.com, and provides Get Emma™, an AI sales agent service, and related commercial services to businesses ("Services"). This policy explains what personal information we collect, why, how we use it, and the choices you have.

This policy applies to three categories of individuals:

• Visitors and clients, people who browse our websites, submit enquiries, or engage us as a client business.
• Client-managed leads and contacts, people whose information a client business stores or manages using Get Emma™ or The Commercial OS.
• Call and message recipients, people contacted by Get Emma™ by voice call, SMS, or social direct message on behalf of a client business.

1. Information we collect

Information you give us directly

• Name, email address, phone number and business details submitted through our contact, opt-in, or booking forms.
• Information you provide during a discovery call, strategy session, or in written correspondence with us.
• Information provided by a client business when configuring Get Emma™ for their own use, including their sales scripts, qualification criteria, and business information.

Information collected automatically

• Standard web analytics data (pages visited, referral source, device and browser type, approximate location derived from IP address).
• Cookies and similar tracking technologies used for site functionality and analytics. See section 8 below.

Information collected when Get Emma™ contacts someone on behalf of a client

When a client business deploys Get Emma™, Emma may contact that business's own leads and customers by voice call, SMS, or social direct message, strictly on the client's instructions and using contact details the client already holds or has lawfully collected. In the course of that contact, we may collect and process:

• The individual's name, phone number, and any information volunteered during the call or message exchange.
• A recording and transcript of the call, where call recording is enabled by the client business and disclosed to the individual at the start of the call.
• Qualification outcomes (for example, whether the individual met the client's stated criteria) and booking details, which are passed back to the client's own systems.

In this context, the client business is the data controller for the personal information of their own leads and customers. We act as a data processor, handling that information on the client's behalf and under the client's instructions.

2. How we use information

• To provide, operate, and improve our Services, including configuring, testing, and tuning Get Emma™ for a specific client's use.
• To respond to enquiries, run discovery calls and strategy sessions, and process bookings made through our forms.
• To send confirmations, reminders, and follow-up communications related to a booking or enquiry.
• To understand how our websites are used, so we can improve them.
• To meet legal, regulatory, and contractual obligations.

We do not sell personal information to third parties, and we do not use client or lead data to train our own AI models.

3. Artificial intelligence disclosure

Get Emma™ is openly artificial intelligence. She does not claim to be human. If asked whether she is AI, she confirms this plainly. Where a call is recorded, that is disclosed to the individual at the start of the call in accordance with applicable law in the jurisdiction the call is made in or received in.

Get Emma™ is created, configured, and run by Skilled Coaching. Delivering her conversational voice and messaging capability relies on underlying AI and voice processing infrastructure provided by our technology partners. Content processed through this infrastructure is used solely to deliver the service in real time, and is not used to train any third party's general-purpose AI models.

4. Who we share information with

We do not sell, rent, or trade personal information. We share information only with the service providers below, each of which processes only the data needed for their specific function.

We may also share information with professional advisers, regulators, or authorities where required by law or to protect our legal rights, and in connection with a merger, acquisition, or sale of business assets, subject to this policy or a policy at least as protective.

5. Agency and client responsibilities

Where a client business uses Get Emma™ or The Commercial OS to manage their own leads and contacts, that client is the data controller for that information. We act as a data processor, processing it on the client's instructions.

Client businesses are responsible for obtaining lawful consent from their own contacts before we contact them on the client's behalf, configuring appropriate call disclosure and recording consent language for their jurisdiction, complying with telemarketing and recording consent laws that apply to them, and setting appropriate retention periods for their own data. A data processing agreement is available on request.

6. Data retention

We retain personal information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Call recordings and transcripts collected on behalf of a client business are retained in accordance with our agreement with that client, and are deleted or returned on request, subject to any legal retention requirement. Billing and financial records are retained for as long as required under applicable tax and legal obligations.

7. International data transfers

We operate across Australia, New Zealand, the United Kingdom, and the United States, and our service providers may process data in the United States or other jurisdictions. Where personal information is transferred internationally, including from the UK or EU/EEA, we take reasonable steps to ensure it continues to be protected in a manner consistent with this policy, including through contractual safeguards such as Standard Contractual Clauses where applicable.

8. Cookies and tracking technologies

Our websites use cookies for essential site functionality, authentication, and analytics. We do not use third-party advertising or cross-site tracking cookies. You can control cookies through your browser settings, though disabling them may affect how parts of our site function.

9. Your rights

Depending on where you are located, you may have the right to access, correct, or request deletion of your personal information, object to or restrict certain processing, request a copy of your information in a portable format, withdraw consent at any time, and lodge a complaint with your local privacy regulator.

Where Get Emma™ has contacted you on behalf of one of our client businesses, we may need to direct your request to that business, since they are the data controller for that information.

To exercise any of these rights, contact us using the details in section 13. We will respond within a reasonable time, and in any event within any period required by applicable law.

10. Security

We use reasonable technical and organisational measures to protect personal information, including encrypted data transmission and access controls appropriate to the sensitivity of the data. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

11. Children's privacy

Our Services are directed at businesses and business owners and are not intended for anyone under 18. We do not knowingly collect personal information from minors. If you believe a minor's information has been collected through our Services, contact us and we will take steps to delete it.

12. SMS messaging and mobile information

This section applies to people who give us their mobile number through our websites and agree to receive calls and text messages from Emma, our AI sales agent. The program details, including message types, frequency and how to opt out, are in section 15 of our Terms of service.

• What we collect. Your mobile number, the content of messages you send and receive, delivery information, and a record of your consent: which form you used, when you submitted it, and the consent wording shown.
• How we use it. To send the messages you agreed to: replies to your questions, follow-ups about your enquiry, and appointment confirmations and reminders. We also use it to honour your opt-out.
• Opting out. Reply STOP at any time and we will stop texting you. Reply HELP for help, or contact us using the details in section 13.
• Records we keep. We keep your opt-out and consent records for as long as needed to show we have followed your instructions and to meet our legal obligations.

We do not share mobile phone numbers, or text messaging opt-in data and consent, with third parties or affiliates for their marketing or promotional purposes. This information is shared only with the service providers listed in section 4, which process it on our behalf to deliver messages and for no other purpose.

13. Contact us

If you have questions about this policy or wish to exercise your privacy rights, contact us at:

Boomalex Pty Ltd, trading as Skilled Coaching
245 Gympie Rd, Kedron QLD 4031, Australia
[email protected]

14. Changes to this policy

We may update this policy from time to time. The "last updated" date at the top of this page reflects the most recent revision. For material changes, we will take reasonable steps to notify affected users. Continued use of our Services after a change constitutes acceptance of the updated policy.