Legal
Privacy Policy
Last updated 26 August 2026
Coaching means you hand over information about your body, your health and your habits. This policy sets out exactly what we collect, why, who sees it, and how you get it back or corrected.
1. Who this policy covers
This policy applies to Ironberg Performance, operated by Daniel Malmberg, sole trader, ABN 46 116 780 296, of Drummoyne, New South Wales, Australia.
Because we collect and hold health information in the course of providing our services, we treat ourselves as bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles, and we do not rely on the small business turnover exemption. We handle your information on that basis regardless of our size.
2. What we collect
Personal information
- Name, email address, phone number, and general location or time zone.
- Application and onboarding answers, including your goals, training history and lifestyle.
- Billing information. Card details are entered directly with our payment processor and are never stored by us.
- Records of our correspondence, coaching calls and check-ins.
Health and sensitive information
The following is sensitive information under the Privacy Act and gets a higher level of protection. We collect it only with your consent and only where it is reasonably necessary to coach you safely:
- Injury history, current pain, medical conditions, surgeries and medications you choose to disclose.
- Body weight, body composition measurements, girths and progress photographs.
- Training logs, performance data, sleep, stress and recovery markers.
- Nutrition intake and dietary requirements.
- For The Crucible only: pathology and blood diagnostic results, and summaries from the reviewing medical practitioner.
The Bulletproof Score
If you use our free Bulletproof Score tool and choose to unlock the full breakdown, we collect your first name and email address, together with the training numbers you entered: your bodyweight, units, estimated one-rep maxes, any row time, your sex, and your age bracket. We also store the score and the weak link the tool identified.
Bodyweight, sex and age are treated as health information under this policy and given the same protection as any other client health data. Entering numbers into the calculator does not send us anything. Nothing leaves your browser until you submit the unlock form.
Technical information
- Basic website usage data such as pages viewed, referring site, approximate location and device or browser type, where analytics is in use.
- The Bulletproof Score stores your entries and a single unlock flag in your own browser using
localStorage, so the page remembers you if you come back. That data stays on your device and we cannot read it. Clearing your browser storage removes it.
3. Why we collect it
- To generate and send you your Bulletproof Score breakdown, and to send you training material by email if you unlocked it. Every email carries a one-click unsubscribe and we stop immediately.
- To assess whether a program is a suitable and safe fit for you.
- To design, deliver and adjust your training and nutrition programming.
- To monitor progress against your baseline and re-test outcomes.
- To communicate with you, answer questions and provide support.
- To process payments and keep required financial records.
- To meet our legal obligations.
We do not sell your information. We do not share it with advertisers.
4. Progress photographs and testimonials
Progress photographs are collected for coaching purposes only. We will never publish your photograph, name, results or a testimonial without your separate, express, written consent, given specifically for that use.
If you have previously given consent, you may withdraw it at any time by emailing us. We will remove the material from our website and from any channel we control as soon as reasonably practicable, though we may not be able to recall material already downloaded or reshared by third parties.
5. Who we disclose it to
We disclose your information only where it is necessary to deliver the service:
| Recipient | Purpose | What is shared |
|---|---|---|
| CoachRx | Programming delivery, logging and coach messaging | Name, contact details, training and body composition data |
| Tally | Application and enquiry forms | What you enter into the form |
| Kit (formerly ConvertKit) | Sending your Bulletproof Score breakdown and any training emails you opted into | First name, email, and the score, weak link and training numbers listed above |
| Payment processor | Taking and managing recurring payments | Name, email, billing details. Card data goes directly to them |
| Email and cloud storage providers | Correspondence and secure file storage | Correspondence and coaching records |
| Reviewing medical practitioner (The Crucible only) | Pathology requests and clinical review | Relevant health information, with your consent |
| Accountant, and regulators or courts where required by law | Financial records and legal compliance | Only what is required |
Some of these providers store data on servers outside Australia, including in the United States and the European Union. Kit, our email provider, is United States based, so if you unlock a Bulletproof Score your name, email and training numbers are stored in the United States. Where we disclose information overseas, we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles, but overseas providers are also subject to the laws of their own country.
6. How we store and protect it
- Information is held in access-controlled accounts protected by strong, unique passwords and multi-factor authentication where available.
- Progress photographs and health records are kept separate from general correspondence and are not stored on shared or public folders.
- Access is limited to Daniel Malmberg and any coach directly assigned to you.
- We keep coaching records for 7 years after your last engagement, which reflects standard record-keeping practice for health-related and financial records, then securely delete or de-identify them.
- Progress photographs are deleted on request at any time, and by default when your coaching records are destroyed.
No system is completely secure. If a data breach occurs that is likely to result in serious harm, we will notify you and the Office of the Australian Information Commissioner as required under the Notifiable Data Breaches scheme.
7. Marketing emails
If you unlock a Bulletproof Score, you are consenting to receive your breakdown plus occasional training material from us. That consent is the only basis on which we email you, and it is easy to withdraw.
- Every email identifies Ironberg Performance as the sender and carries a working one-click unsubscribe link, as required by the Spam Act 2003 (Cth).
- Unsubscribes take effect immediately and always within 5 business days.
- We do not sell, rent or share our email list.
- Unsubscribing stops the emails. If you also want your record deleted, email us and we will remove it.
8. Cookies and analytics
Our website uses only what is necessary to function. If we use analytics, it is limited to aggregate usage measurement, and we do not use it to build advertising profiles or to track you across other websites. You can block cookies in your browser settings without losing access to the site.
9. Accessing and correcting your information
You can ask us at any time to:
- tell you what personal or health information we hold about you;
- give you a copy of it;
- correct anything that is inaccurate, out of date or incomplete;
- delete your progress photographs or withdraw a publication consent;
- unsubscribe from our emails, or have your Bulletproof Score record deleted from Kit entirely;
- delete your other information, where we are not required by law to keep it.
Email dan@ironbergperformance.com. We will respond within 30 days. There is no charge for a reasonable request. We may need to verify your identity first.
10. Complaints
If you think we have mishandled your information, contact us first at dan@ironbergperformance.com. We will acknowledge within 5 business days and give you a written response within 30 days.
If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.
11. Changes to this policy
We may update this policy. The version on this page is the current one and the date at the top shows when it last changed. If a change materially affects how we handle your information, we will notify clients by email.
Privacy contact
Daniel Malmberg, Ironberg Performance
ABN 46 116 780 296 · Drummoyne, Sydney NSW, Australia
