PRIVACY POLICY - Rewritten April 2026
1. Who this policy applies to
This policy applies to anyone who:
• Visits markwinter.com.au or pragmaticchange.com.au
• Uses Pragma, the AI change advisor
• Submits their email address through any form on these platforms
2. Who we are and the Privacy Act
Mark Winter is a sole trader operating under Australian Business Number 93 702 623 408.
As a small business operator, Mark Winter may not be legally required to comply with all provisions of the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). However, this policy commits to compliance with the APPs as a matter of good practice. Where the Privacy Act applies — whether now or as the business grows — it governs.
If you have questions about anything in this policy, email mark@flamenetwork.com.au.
3. What information we collect, why we collect it, and what we do with it
3.1 Conversation data (Pragma)
What we collect: When you use Pragma, we collect the content of your conversation — your messages and Pragma's responses — and store them in a database.
Why: To review and improve the quality of Pragma's responses. Mark Winter periodically reviews conversations to identify where Pragma's guidance could be stronger, more accurate, or better calibrated to real practitioner experience.
How long we keep it: Conversation data is retained for a rolling 12-month period and then deleted, unless we are required by law to retain it for longer.
What you need to know:
• Your conversations may be read by Mark Winter as part of quality review.
• Your conversations will not be shared publicly or attributed to you by name.
• Anonymised patterns from conversations may inform updates to Pragma's knowledge base.
• Do not submit confidential commercial information, personal information about identifiable third parties, or legally privileged material through Pragma. If you do, that information will be processed as described in this policy.
Legal basis for collection: Your consent, given when you accept these terms and begin using Pragma. See section 6 on how to withdraw consent.
3.2 Email addresses
What we collect: If you register interest in Pragma Premium or opt in to product update notifications, we collect your email address.
Why: To notify you when features you have expressed interest in become available.
How long we keep it: Until you unsubscribe or ask us to delete it, or until Pragma ceases to operate. We will retain email addresses for no longer than 30 days after an unsubscribe request is received.
What you need to know:
• Your email address will only be used for the purpose you provided it.
• We will not send you commercial marketing without your consent.
• Every email communication from us will include an unsubscribe link, in accordance with the Spam Act 2003 (Cth).
3.3 Website analytics
What we collect: markwinter.com.au uses Google Analytics 4 to collect aggregated data about how visitors use the site — pages viewed, time on site, and referral sources.
Why: To understand which content is useful and how the site can be improved.
How long we keep it: In accordance with Google Analytics 4 default retention settings (14 months).
What you need to know:
• This data is aggregated and does not directly identify you as an individual.
• Google Analytics transfers data to Google's servers in the United States. See section 4 on cross-border disclosure.
4. Who your information is shared with — including overseas recipients
Your personal information is processed by the following third-party services, some of which are located outside Australia. We are required to tell you about this under Australian Privacy Principle 8 (APP 8).
Important: By using Pragma and this website, you consent to your personal information being disclosed to the overseas recipients listed in the table below. If you provide this consent, we are not required under APP 8.1 to take further steps to ensure those overseas recipients comply with the APPs, and we will not be responsible for their handling of your information. Each recipient operates under their own privacy policy, linked below.
For a full list of third-party services and their privacy policies, see: Anthropic (Claude AI) — anthropic.com/privacy · Lovable — lovable.dev/privacy · Squarespace — squarespace.com/privacy · Airtable — airtable.com/privacy · Stripe — stripe.com/au/privac
Your information is not sold to third parties. It is not used for advertising. It is not shared with any party not listed in this section.
Note on Anthropic: Conversations sent to Pragma are processed by Anthropic's API. In addition to their privacy policy, Anthropic's API terms permit processing of conversations for safety monitoring and related safety research. We do not control Anthropic's data practices beyond what their API terms govern. We recommend reviewing Anthropic's API usage policy at anthropic.com/legal/aup in addition to their privacy policy.
5. How we protect your information
Conversation data is stored in Lovable's secure cloud infrastructure. Email addresses are stored in Airtable, which uses industry-standard security including encryption at rest and in transit. Stripe (for payment processing, when Premium launches) is PCI DSS compliant.
No system is completely secure. If we become aware of a data breach that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner (OAIC) as soon as reasonably practicable and within 30 days of becoming aware of the breach.
6. Your rights
You have the right to:
• Access the personal information we hold about you
• Request correction of information that is inaccurate, incomplete, or out of date
• Request deletion of your personal information (subject to any legal obligation to retain it)
• Withdraw consent for conversation review or email communications at any time
• Make a complaint about how we have handled your personal information
To exercise any of these rights, email mark@flamenetwork.com.au or contact Mark via LinkedIn. We will respond within 30 days.
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 by calling 1300 363 992.
7. Cookies and tracking
markwinter.com.au uses cookies for website analytics (Google Analytics 4). You can disable cookies through your browser settings; doing so may affect website functionality.
Pragma uses browser session storage and local storage to maintain your conversation within a browser session. This local data is not transmitted to third parties other than those listed in section 4. Conversation content sent to Pragma is stored in our database as described in section 3.1.
8. Changes to this policy
This policy may be updated from time to time. The date at the top of this page reflects the most recent revision. We will notify you of material changes by posting a notice on this page and, where we hold your email address, by email to that address.
9. Contact and complaints
Mark Winter
Email: mark@flamenetwork.com.au
Website: markwinter.com.au
ABN: 93 702 623 408
This policy covers personal information collected through markwinter.com.au, pragmaticchange.com.au, and Pragma. It does not cover information collected through consulting or coaching engagements with Mark Winter, which is governed by separate engagement terms.
