ATILE WELLNESS HUB

PRIVACY POLICY

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1 INTRODUCTION

This document sets out the privacy policy of Atile Wellness Hub Pty Ltd ACN
652 321 518 (referred to in this privacy policy as “we”, “us”, or “our”).

We take our privacy obligations seriously and we’ve created this privacy policy to explain how we store, maintain, use and disclose personal information.

By providing personal information to us, you consent to our storage, maintenance, use and disclosing of personal information in accordance with this privacy policy. We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.

2 LAWS AND STANDARDS WE COMPLY WITH

To the extent that the following applies to us and our use of your information, we comply with:
(a) the Australian Privacy Principles established by the Privacy Act 1988 (Cth); and
(b) the Health Records and Information Privacy Act 2002 No 71 (NSW) (HRIPA), including Part 4 (Provisions for private sector persons) of the HRIPA.

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3 TYPES OF PERSONAL INFORMATION WE COLLECT

The personal information we collect may include the following:
(a) name;
(b) mailing or street address;
(c) email address;
(d) social media information;
(e) telephone number and other contact details;
(f) age;
(g) date of birth;
(h) credit card or other payment information;
(i) sensitive information (including health information) as set out in clause 7 ;
(j) information about your business or personal circumstances, including information disclosed in the course of any coaching and counselling sessions with you and as part of supervision or training of our coaches and/or counsellors;
(k) information in connection with client surveys, questionnaires and promotions;

(l) your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information;
(m) information about third parties; and
(n) any other information provided by you to us via our website or our online presence, or otherwise required by us or provided by you.

4 HOW WE COLLECT PERSONAL INFORMATION
(a) We may collect personal information either directly from you, or from third parties, including where you:
(i) contact us through our website or in person;
(ii) receive goods or services from us;
(iii) submit any of our online sign up forms;
(iv) communicate with us, in person or via email, telephone, SMS, social
applications (such as LinkedIn, Facebook or Twitter) or otherwise;
(v) interact with our website, social applications, services, content and advertising; and
(vi) invest in our business or enquire as to a potential purchase in our business.
(b) We may also collect personal information from you when you use or access our website or our social media pages. This may be done through use of web analytics tools, ‘cookies’ or other similar tracking technologies that allow us to track and analyse your website usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. If you do not wish information to be stored as a cookie, you can disable cookies in your web browser.
(c) We may use Google Analytics to collect and process data, including when you use third party websites or apps. To find out more see How Google uses data when you use our partners’ sites or apps.

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5 USE OF YOUR PERSONAL INFORMATION
5.1 GENERAL
(a) We collect and use personal information for the following purposes:
(i) to provide services or information to you;
(ii) for record keeping and administrative purposes;
(iii) to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing services to you;
(iv) to refer you to medical or health service providers;
(v) to comply with our legal obligations (including any professional code of conduct or legislative requirements relating to any aspect of our coaching or counselling services, including supervision or training), resolve disputes or enforce our agreements with third parties;
(vi) to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act). In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
(vii) for our legitimate interests including:
(A) to develop and carry out marketing activities and to conduct market
research and analysis and develop statistics;

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(B) to improve and optimise our service offering and customer
experience;
(C) to send you administrative messages, reminders, notices, updates,
security alerts, and other information requested by you;
(D) to consider an application of employment from you; and
(E) the delivery of our services.

(b) We may disclose your personal information to cloud-providers, contractors and other third parties located inside or outside of Australia. If we do so, we will take reasonable steps to ensure that any overseas recipient deals with such personal information in a manner consistent with how we deal with it.

5.2 SHARING OF YOUR INFORMATION
(a) We may need to share your personal information with third parties, including your medical providers that we work with to provide you with our services. As part of their professional development, our coaches and/or counsellors may also share personal information to registered supervisors from the Australian Counselling Association from time to time. Any information that we share to registered supervisors will be de-identified in accordance with clause 5.3 . You consent to the sharing of your personal and sensitive information with these third parties as required to provide you with the services.
(b) We will never share your personal information with the intent of deriving a profit or receiving a benefit from this information outside of the specific purposes outlined in this privacy policy.

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5.3 COMMERCIAL, MARKETING, RESEARCH, EDUCATION AND TRAINING
(a) We may also share information with third parties for commercial, marketing, research, education or training purposes. Any information that we share for this purpose will be de-identified prior to sharing.
(b) If we collect any personal information from you and we are unable to de-identify that personal information, we will obtain your consent before sharing that information for any commercial, marketing, research, education or training purposes set out in this clause.

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6 PROVIDING INFORMATION FOR SOMEONE ELSE
(a) If you are providing personal and/or sensitive information on behalf of someone else, you must have the consent of that person to provide their personal and/or sensitive information to us to be collected, used and disclosed in accordance with this privacy policy. We reserve the right to request evidence of this consent.
(b) If you are providing personal and/or sensitive information on behalf of someone under the age of 18 (Minor), you must be that Minor’s parent or legal guardian and you must provide consent for the Minor’s personal and/or sensitive information to be collected, used and disclosed in accordance with this privacy policy.

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7 SENSITIVE INFORMATION
(a) We may collect sensitive information about you during the course of providing you services. The type of sensitive information we may collect includes: information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices or
health information.
(b) We will collect this sensitive information where you consent and provide us with this information. If you consent, your sensitive information may only be used and disclosed for purposes relating to providing you with our services and data analytics and/or referring you to medical or health service providers.
(c) We may not be able to obtain your consent in certain circumstances. For instance, we will not obtain your consent if there is an emergency or you are cause imminent risk and serious harm to yourself or another person, or to public health and safety. We may also use your sensitive information to comply with our legal obligations. We are required or authorised by or under an Australian law, or a court/tribunal order, to disclose sensitive information.

8 SECURITY

We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal information.

9 LINKS

Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.

10 REQUESTING ACCESS OR CORRECTING YOUR PERSONAL INFORMATION
(a) If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your
personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.
(b) If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.
(c) For the avoidance of doubt, we will not change any personal information that we hold about you for any illegitimate reasons.

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11 COMPLAINTS

If you wish to complain about how we handle your personal information held by us, please contact us using the details set out below including your name and contact details. We will investigate your complaint promptly and respond to you within a reasonable timeframe.

12 CONTACT US

For further information about our privacy policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
Name: James Hinton
Email: info@atilewellnesshub.com

Our privacy policy was last updated on 14 July 2022.