TWP Club Privacy Policy

1. Introduction and Scope

Welcome to TWP Club (referred to as "the Company," "we," "us," or "our"). TWP Club is a specialised consulting, marketing, lead generation agency operated under the corporate identity of The Wealthy People Club. We act as an intermediary platform designed to connect interested individuals, investors, and clients with trusted external service providers, professional advisers, and third-party firms. This Privacy Policy governs the collection, storage, use, protection, and disclosure of personal information obtained from members, users, and clients (referred to as "you" or "your") who interact with our digital assets, respond to our marketing, or utilise our referral infrastructure.

We operate primarily within Australia and commit strictly to compliance with Australian legislation. This includes the Privacy Act 1988 (Cth), the Australian

Privacy Principles (APPs), the Spam Act 2003 (Cth), and the Do Not Call Register Act 2006 (Cth). While our focus remains on Australian residents, our digital resources are accessible globally, and we maintain high standards of data security for all users. By interacting with our website, landing pages, marketing campaigns, or communication channels, you explicitly acknowledge and consent to the data practices outlined in this policy.

2. Information We Collect

To provide effective matching, educational content, and referral services, we must collect specific categories of personal and non-personal data. We collect this data only through lawful, fair, and transparent means.

2.1 Personal Information Provided Voluntarily

When you sign up for a free membership, request a "Game Plan," download resources, or submit a request for an external provider referral, you may provide:

Full name, age, and date of birth (membership is strictly restricted to individuals aged 18 and older).
Contact details, including your primary email address, residential address, and phone number.
Financial profiles, investment preferences, risk tolerance parameters, and current asset or debt structures.
Specific service requests, such as inquiries regarding property purchases, loan refinancing, insurance reviews, tax structures, or estate planning.

2.2 Information Collected via Marketing and Sourcing Channels

We actively source potential clients through diverse marketing infrastructures to deliver tailored information. This includes:

Outbound Marketing Campaigns: Direct outreach via telephone or digital correspondence.
SMS Marketing: Short Message Service campaigns sent to individuals who have opted into receiving promotional communications.
Purchased Leads: High-quality, verified data segments acquired from trusted, compliant third-party data suppliers who warrant that appropriate consumer consent has been obtained.
Digital Advertising: Information captured via data submission forms on platforms such as Facebook Ads, Google Ads, Instagram, and LinkedIn.

2.3 Automated and Technical Data Collection

When navigating our digital platforms, we automatically collect tracking metrics:

IP addresses, browser types, operating systems, and device identifiers.
Clickstream data, page response times, download errors, and duration of visits to specific pages.
Data obtained via cookies, tracking pixels, and web beacons to optimise ad delivery and improve user interface performance.

3. How We Use Your Information

TWP Club uses your personal information primarily as a marketing and referral conduit. Specific primary and secondary purposes include:

3.1 Facilitating Referrals to External Providers

The core function of TWP Club is to source clients and match them with external service providers (e.g., mortgage brokers, financial planners, legal professionals, real estate specialists, accountants). We use your specified needs and personal details to determine which external provider is best suited to fulfil your request.

3.2 Proactive Membership and Calendar Reminders

If you hold a free membership, we use your details to operate our personalised financial calendar system. This includes sending automated and manual reminders for critical financial check-ups, such as:

Important fiscal and tax year dates.
Prompts to review personal or business insurance coverage.
Reminders to evaluate property loans for potential refinancing.
Strategic prompts to create or update estate planning documents, wills, and powers of attorney.

3.3 Platform Administration and Content Optimisation

We use your data to manage your account, deliver educational materials (such as webinars, articles, and e-books), verify your age and jurisdiction, and monitor the safety and integrity of our digital platform. Noting that some of the administration is managed by our fully customised A.I Agents (A.I Bots) that are programmed to be available for members 24 hours, 7 days a week.

4. Data Sharing and Disclosure

We maintain a strict stance on data integrity: TWP Club does not sell your personal data to general third-party brokers, nor do we disclose it without explicit legal grounds or your directed consent.

4.1 Disclosure to External Service Providers

By submitting an inquiry, requesting a "Game Plan," or asking for an introduction to an expert, you give your explicit consent for TWP Club to forward your personal data, contact information, and specific requirements to selected external service providers. Once your data is transferred to a referred provider, that data becomes subject to the independent privacy policy and professional standards of that specific provider.

4.2 Corporate and Legal Disclosures

We may disclose your personal information under the following limited conditions:

To third-party IT contractors, software-as-a-service (SaaS) platforms, and database administrators who host or service our systems under strict confidentiality agreements.
To professional advisers, insurers, or legal consultants protecting the business interests of TWP Club.
When compelled by law, court order, regulatory body (such as ASIC or OAIC), or law enforcement agency.

5. Data Security and Retention

We take data protection seriously and implement industry-standard technical and organisational measures to protect your information against unauthorised access, loss, alteration, or disclosure. These measures include encrypted data transfers, secure firewalls, restricted access protocols, and monitored storage servers.

We retain your personal information only for as long as necessary to fulfil the primary purposes of collection, including satisfying legal, accounting, or reporting requirements. When personal data is no longer required, we take definitive, secure steps to permanently de-identify or destroy it. Despite our robust security measures, no digital transmission or storage system can be guaranteed 100% secure. You acknowledge that you provide your data at your own risk.

6. Access, Correction, and Your Rights

Under the Australian Privacy Principles, you possess clear rights regarding your personal information:

Access: You have the right to request a copy of the personal information we hold about you.
Correction: You may request that we update, amend, or correct any inaccurate, incomplete, or out-of-date personal data.
Opt-Out/Unsubscribe: You can revoke your marketing consent at any time. Every marketing email or SMS sent by TWP Club features an explicit "Unsubscribe" or "STOP" link. Alternatively, you can contact us directly to be placed on our internal "Do Not Contact" register.

To exercise any of these rights, please submit a formal request via email to our designated Privacy Officer at our official corporate contact address. We will process your request within 30 days, subject to identity verification.

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TWP Club TERMS AND CONDITIONS

1. Nature of Services and No Investment Advice

TWP Club is a paid membership marketing platform, client-sourcing network, and educational hub. TWP Club is not a financial services licensee, a law firm, a registered tax agent, or a licensed credit provider.

1.1 Educational Content Only

All materials hosted on our site, distributed via email, shared during webinars, or conveyed through social media platforms are purely for general educational and informational purposes. No content constitutes personalized financial, investment, legal, credit, or tax advice. The information provided does not take into account your individual financial situation, objectives, or specific needs.

1.2 Independent Research Mandate

We strongly recommend and mandate that every member conducts thorough, independent research before executing any investment or financial strategy. Any decisions made, actions taken, or commitments entered into based on content found on TWP Club are entirely your own responsibility. You must consult with qualified, independent, and licensed financial, legal, credit, and tax professionals before finalizing any transaction.

1.3 No Performance Guarantees

TWP Club makes no warranties or guarantees, express or implied, regarding the performance, profitability, safety, or suitability of any investment strategy, asset class, or external service provider mentioned on or referred through our platform. Historical performance data is not indicative of future results. You acknowledge that all investments carry inherent risk, including the loss of capital.

2. Formation of Engagement

By navigating this website, reading our materials, or subscribing to our free general newsletter, no formal client-agency relationship or professional engagement is established between you and TWP Club.

A formal engagement with TWP Club for specific sourcing or referral services is initiated exclusively when you make an explicit request for a "Game Plan" or formally ask us to connect you with an external service provider. Until that point, your interaction is classified as educational exploration, information gathering, and intellectual inquiry.

3. Referral Framework and Client Responsibilities

When you request a referral or a "Game Plan," TWP Club acts as a matching facilitator. We introduce you to third-party professionals who operate completely independent businesses from TWP Club.

3.1 Vetting and Due Diligence

While TWP Club endeavors to source referrals from reputable, experienced external providers, we do not control, supervise, or accept liability for the actions, omissions, advice, contracts, or services provided by those external entities. It is your sole responsibility to review their official documents, credentials, regulatory licenses, guarantee certificates, and legal contracts before executing any transaction with them.

3.2 Independent Contracts

Any professional relationship, contract, or financial transaction you enter into with an external provider referred by us is strictly between you and that third party. TWP Club is not a party to those agreements and disclaims all liability arising from such arrangements.

4. Non-Circumvention Policy

TWP Club operates a business model dependent on sourcing clients and referring them to external service providers. Our revenue and commercial viability depend on the integrity of our referral tracking infrastructure. To safeguard our business operations and protect our revenue streams, you agree to the following legally binding Non-Circumvention terms:

By requesting a "Game Plan" or initiating a referral inquiry, you explicitly acknowledge that the introduction made by TWP Club to any external service provider is a proprietary and commercially protected business asset. The formal pipeline originates when you submit your requirements, progresses through our secure tracking infrastructure, and concludes with the direct handoff of your profile to an independent professional. This structured introduction forms the sole basis of the relationship with that provider, and you agree that this connection is directly attributable to TWP Club’s marketing and sourcing operations.

Consequently, you are under a strict contractual obligation to provide complete transparency regarding any subsequent transactions. Upon written, verbal, or electronic request by TWP Club, you must promptly and fully disclose the exact status, nature, and extent of any services consumed, agreements signed, or financial transactions finalized with the introduced business. Failure to provide this accurate disclosure within seven (7) days of an inquiry constitutes a material breach of these Terms, directly undermining our revenue-tracking infrastructure and giving TWP Club the immediate right to seek legal remedies.

4.1 Duty of Disclosure and Forthcomingness

You agree to act with complete transparency, honesty, and good faith in all dealings with TWP Club regarding any external service provider we have introduced to you. If asked by a representative of TWP Club via email, telephone, SMS, or written questionnaire whether you have engaged, contracted with, or received services from a referred business, you are contractually obligated to provide a complete, prompt, and accurate disclosure.

4.2 Prohibition of Circumvention

You explicitly agree not to bypass, circumvent, or avoid the tracking, reporting, or commercial mechanisms established between TWP Club and its network of external service providers. You must not arrange private terms, direct transactions, or undisclosed agreements with a referred provider with the intent or effect of concealing that the relationship originated through TWP Club's sourcing efforts.

4.3 Remedies for Breach

If you violate this Non-Circumvention policy by providing false information regarding your engagement with a referred provider, or by failing to disclose an active engagement when asked, you cause direct financial harm to TWP Club's revenue. In such events, TWP Club reserves the right to immediately terminate your membership, bar you from all future platform access, notify the relevant external provider of the contractual breach, and pursue all available legal and equitable remedies to recover lost revenue or tracking fees under applicable contract law.

5. Use of Artificial Intelligence (AI) and Error Acknowledgment

TWP Club prioritises efficiency and thematic consistency across our extensive educational catalogue. During the creation of certain documentation we may employ A.I tools to assist in the creation or editing of documentation, as such it cannot be guaranteed that all information is always accurate, any errors in documentation are to be accepted as accidental in nature and any specific losses as a result of an error related to documentation created or edited by A.I

5.1 AI-Generated and Assisted Content

You acknowledge and agree that our marketing materials, website copy, articles, emails, and financial calendar communications are written, compiled, or run through Artificial Intelligence (AI) writing and editing tools. This process is utilised to ensure standard formatting, cross-platform readability, and a unified brand theme. You accept that A.I may be used in the administration and delivery of services by TWP Club.

5.2 Acceptance of Accidental Errors

Because AI technologies are utilised during our publishing and content generation workflows, technical anomalies, editorial oversight, or factual inaccuracies may occasionally occur. You accept that any such mistakes, typos, or administrative errors are accidental. You agree that no content produced via these tools shall be deemed fraudulent or intentionally misleading. It remains your absolute responsibility to independently verify all information through your own licensed, human advisors before making any financial commitments.

6. Limitation of Liability and Indemnity

To the maximum extent permitted by the laws of Australia, including the Australian Consumer Law, TWP Club, its directors, employees, affiliates, software partners, and marketing agents shall not be liable for any direct, indirect, incidental, consequential, special, or exemplary damages. This includes, but is not limited to, damages for loss of profits, capital depletion, goodwill, data loss, or other intangible losses resulting from:

Your use of or inability to use the TWP Club platform or educational materials.
Any financial, investment, or legal decisions you make without obtaining independent professional advice.
The actions, advice, representation, or contract performance of any external service provider introduced to you by TWP Club.
Any accidental errors, omissions, or formatting discrepancies within our AI-assisted content.

You agree to indemnify, defend, and hold harmless TWP Club, its officers, directors, and employees from and against any claims, liabilities, damages, losses, costs, or expenses (including reasonable legal fees) arising out of your breach of these Terms and Conditions, your reliance on platform content as personalized advice, or your breach of the Non-Circumvention policy.

7. Governance and Modifications

7.1 Governing Law

These Terms and Conditions and our Privacy Policy are governed by and construed in accordance with the laws of the State of New South Wales, Australia. You irrevocably submit to the exclusive jurisdiction of the courts of that State and courts entitled to hear appeals from those courts.

7.2 Severability

If any provision of these Terms or Privacy Policy is found to be invalid, unlawful, or unenforceable by a court of competent jurisdiction, that provision will be severed. The remaining provisions will continue in full force and effect.

7.3 Amendments to Policies

We regularly update our operational practices, marketing mechanisms, and legal terms to adhere to changing commercial regulations and industry best practices. TWP Club reserves the right to amend this Privacy Policy and Terms and Conditions at any time without prior individual notice. Any modifications become effective immediately upon being posted to our public website. Your continued use of the platform, responses to our marketing campaigns, or engagement with our referral services following modifications constitutes your definitive acceptance of the updated terms.

PART C: CONTACT AND COMPLIANCE ENQUIRIES

If you have any questions regarding this Privacy Policy, wish to exercise your data access rights, or need clarification regarding the Non-Circumvention obligations within our Terms and Conditions, please reach out to our corporate compliance team: Email: admin@twpclub.com.au with matters made to the Attention of: Privacy Officer / Legal Compliance Department

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