Choose Your Wellness Privacy Policy 

1.     Introduction

1.1.   This website and mobile application are created and controlled by Choose Your Wellness(ABN 34 627 893 396) (we, us or our).

1.2.   We are committed to ensuring your personal information is protected. We manage your personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).

1.3.   By accessing and using our website (www.chooseyourwellness.com.au),mobile application, products or services (collectively, Wellness Platform) you agree to this Privacy Policy.

1.4.   This Privacy Policy outlines how we collect, store, use and disclose your Personal Information, and how you may access your Personal Information (as defined in the Privacy Act) kept by us or how you may make a privacy complaint.

 

2.     The information we collect about you

2.1.   We will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, provide you with access to, and use of, Wellness Platform, advertise or list our service members’ products or services, deliver our products and services to you, or as otherwise permitted by law.

2.2.   The type of Personal Information that we collect and use depends on the type of dealings that you have with us and includes the following: 

(a)     customer member details (for example, full name, address, mobile and telephone numbers and email address);

(b)     service member details (for example, service member, business name, business address, mobile and telephone numbers and email address, description of services offered, availability, qualifications and any other information the service member wishes to share with us and customer members and proof of identity documents, such as driver’s licence or passport);

(c)     information relating to your dealings, or enquiries you have made, with us, including information about the products or services you are interested in or have ordered;

(d)     information relating to your account on the Wellness Platform, including your username and password;

(e)     information from your social media profile when you access the Wellness Platform using social media platforms to the extent that the social media platform allows us to collect such information or you have disabled such functionality, such as your name and other information contained on your social media account;.

(f)      payment and billing information, including identity documents and bank account details;

(g)     information regarding your access, and use of, the Wellness Platform, including location information, IP address,  technical information about your computer or mobile device (such as type of device, web browser or operating system), your mobile device's unique ID number (when available), pages you visit, features you access and how long you visit or use the Wellness Platform ; and

(h)     other information that you provide to us or that we may collect in the course of our relationship with you.

2.3.    We do not collect your Sensitive Information (as defined by the Privacy Act).

3.     How we collect Personal Information

3.1.   We will collect Personal Information about you in a number of different ways. We may collect Personal Information directly from you or in the course of our dealings with you. For example:

(a)     when you contact and correspond with us, when use or order our products or services, visit the Wellness Platform, access the Wellness Platform via a social platform, download our mobile application, contact us online or via telephone with a query;

(b)     from third parties (including our related bodies corporate, business partners, third party service providers, service members and from publicly available sources of information, including publicly available tools, such as Google Analytics, to better understand your preferences.

(c)     when you access the Wellness Platform using social media platforms; or

(d)     when otherwise legally authorised or required to do so.

3.2.   When we collect Personal Information directly from you, we will take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection.

4.     How we use your Personal Information

We use and disclose your Personal Information for the purposes for which the information is collected, including (but not limited to):

(a)     providing you with access to, and use of, the Wellness Platform, providing or delivering our product or services to you or connecting customer members to service members;

(b)     assisting with, or responding to, your queries;

(c)     informing you about our Wellness Platform, service members (including information to relating to our service members’ products and services, availability, qualifications and locations), any other products or services made available to you on, or via, the Wellness Platform, or other matters which we believe are of interest to you (such as recruitment or job opportunities);

(d)     share with our Third Party Providers who use your Personal Information for the purpose of performing functions on our behalf;

administer, improve and manage our products, services and the Wellness Platform (including personalizing content or features on the Wellness Platform that match your profiles or interests);

(e)     perform internal operations necessary to provide our products, services and the Wellness Platform, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;

(f)      charge and bill you for the use of the Wellness Platform,service members’ products and services and any other products or services made available to you on, or via, the Wellness Platform and pay service members;

(g)     for direct marketing purposes (see section 6 below); and

(h)     complying with our legal and regulatory obligations.

5.     Disclosure to Third Parties

5.1.    In order to provide you with access to, and use of, the Wellness Platform, to advertise and list our service members’ products and services, and to deliver our products or services to you, we may disclose your Personal Information to:

(a)     our related bodies corporate, business partners, service members and other service providers, third party contractors, agents or suppliers, external business advisors or other authorised external service providers who perform functions on our behalf. Examples of these third-party service providers include, but are not limited to, such as marketing and analysis organisations and marketing platforms, data analytics providers, hosting and storage providers, web developers, internet service providers, software security vendors, customer service providers, customer support specialists, fulfilment companies, external business advisors (including auditors and lawyers), our insurer, and research and data analysis firms (collectively, Third Party Providers); and

(b)      law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law.

5.2.    Prior to the disclosure of Personal Information to Third Party Providers, we will take such steps as reasonable in the circumstances to ensure that the Third Party Providers treat your Personal Information securely and otherwise complies with the relevant Australian Privacy Principles in relation to the Personal Information.

5.3.    We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not collect, process, use, share, store or disclose any Personal Information or payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party processor, Paypal and Stripe, whose use of your personal Information is governed by their privacy policy, which may be viewed at www.paypal.com/au/webapps/mpp/ua/privacy-full and https://stripe.com/au/privacy.

6.     Marketing communications

6.1.   We may use and disclose your Personal Information to send you information about service members’ products and services and any other products or services we offer, as well as other information that may be of interest to you. We may send this information in a variety of ways, such as by mail, email, SMS, telephone, social media or by customising online content and displaying advertising on our website.

6.2.   If you do not wish to receive any of these marketing communications, you can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us using the contact details set out in section 12 below. 

7.     Overseas disclosures of Personal Information

7.1.   In the course of providing you with service members’ products and services, our products or services and access to, and use of, the Wellness Platform, it may become necessary or desirable to disclose Personal Information to Third Party Providers located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information to Third Party Providers located in the following countries United States, European Union, United Kingdom, Singapore, India and Mexico.

7.2.   The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas we will take reasonable steps to ensure that your Personal Information is treated securely and the means of transfer provides adequate safeguards.

 

8.     Notifiable Data Breaches Scheme

In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach scheme contained in Part IIIC of the Privacy Act.

9.     Security of your Personal Information  

9.1.   We take steps reasonable in the circumstances to ensure that the Personal Information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. 

9.2.   The transmission of information via the Internet is not completely secure. We cannot guarantee the security of your data transmitted to our online services and any transmission is at your own risk.  

9.3.   We invite you to post content on or through the Wellness Platform, including, but not limited to, your comments, pictures, service member profiles and any other information. However, please be careful and responsible whenever you are online. If you choose to post content on or through the Wellness Platform, such as through member-to-member messaging or through our review boards, forums, blogs, or other postings, that information:

(a)     may be or may become publicly available;

(b)     may be collected and used by third parties with or without our knowledge; and

(c)     may be used in a manner that may violate this Privacy Policy, the law, or your personal privacy.

9.4.   We will destroy or de-identify Personal Information in circumstances where it is no longer required, unless we are otherwise required or authorised by law to retain the information.

 

10.     Accessing and correcting your Personal Information

10.1.  We take steps reasonable in the circumstances to ensure Personal Information we hold is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your Personal Information that is collected and held by us.

10.2.  If at any time you would like to access or correct the Personal Information we hold about you, or you would like more information about our approach to privacy, please contact us via the contact details set out in section 12 below. If we refuse your request to access or correct your Personal Information, we will provide you with written reasons for the refusal and details of complaint mechanisms.

 

11.     Cookies

11.1.  We may collect information when you access and use the Wellness Platform by utilising features and technologies of your internet browser, including cookies, pixeled tags, web beacons, embedded web links and similar technologies. A cookie is a piece of data that enables us to track and target your preferences.

11.2.  The type of information we collect may include statistical information, details of your operating system, location, your internet protocol (IP) address, the date and time of your visit, the pages that you have accessed, the links which you have clicked and the type of browser that you were using].

11.3.  We may use cookies and similar technologies to:

(a)      enable us to identify you as a return user and personalise and enhance your experience and use of the Wellness Platform;

(b)      help us improve our service to you when you access the Wellness Platform and to ensure that the Wellness Platform remain easy to use and navigate; and

(c)      analyze site traffic and trends, including estimating and reporting total audience size (unique users);

(d)      determine the popularity of the content of the Wellness Platform and measuring the effectiveness of advertising campaigns.

11.4.  Most browsers are initially set up to accept cookies. However, you can reset your browser to refuse all cookies or warn you before accepting cookies.

11.5.  If you reject our cookies or similar technologies, you may still use the Wellness Platform but may only have limited functionality of the Wellness Platform.

11.6.  We may also use your IP address to analyse trends, administer the Wellness Platform and other websites we operate, track traffic patterns and gather demographic information.

11.7.  Your IP address and other personal information may be used for credit fraud protection and risk reduction.

12.  Contact information

If you have any questions or comments regarding our Privacy Policy, please contact us directly by:

(a)     email at hello@chooseyourwellness.com.au or

(b)     calling us on 0411 371 743.

13.  Changes to this Privacy Policy

From time to time it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on our website. We encourage you to check our website from time to time to ensure you are familiar with our latest Privacy Policy.