WholeLivingSystemsPrivacyPolicy2018

‘Whole Living Systems’ COMMITMENT TO PRIVACY

This Whole Living Systems website (“Website”), run in association with Goodlife Health Clubs (Goodlife), is owned by Loup Pty Ltd ABN 82 164 519 671 trading as Whole Living Systems. Whole Living Systems, its subsidiaries and affiliates in Australia (collectively referred to as (“Whole Living Systems”) are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth), and in accordance with other applicable privacy laws.

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, "we", "us" and “our” refers to Whole Living Systems and "you" refers to any individual about whom we collect personal information.

This Privacy Policy applies to all personal information collected by us, or submitted to us, whether offline or online, including personal information collected or submitted through any of our Website, through our official social media channel pages which we control (such as our LinkedIn page), as well as through email messages that we send to you.

ABOUT WHOLE LIVING SYSTEMS

Whole Living Systems provides a website accessed by members of Goodlife participating in 8 or 12 week challenges run by Goodlife.

The Website provides a range of information services, including relating to workout, nutritional and mental well being.

WHAT INFORMATION DOES WHOLE LIVING SYSTEMS COLLECT ABOUT YOU?

Members and prospective members

If you enquire about the services of any of Whole Living Systems’ or access its Website or when you become a member of Whole Living Systems’ you will be subject to the terms and conditions of this Privacy Policy. The types of information we collect include:

  • name
  • email address
  • age
  • gender
  • questions and answers to security questions and other information that enables us to provide you with an online profile and to verify your identity when using our services.

Other individuals

Whole Living Systems may collect personal information about other individuals. This includes members of the public who interact with Whole Living Systems on a commercial basis.  The kinds of personal information we collect will depend on the capacity in which you are dealing with Whole Living Systems.  Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.

You can always decline to give Whole Living Systems any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested.  If you have any concerns about personal information we have requested, please let us know.

Visitors to our Website

The way in which we handle the personal information of visitors to our Website is discussed below.

What happens if you don’t provide your personal information?

You can always decline to give Whole Living Systems any personal information we request, but that may mean we may not be able to do business with you effectively.  If you have any concerns about personal information we have requested, please let us know.

HOW AND WHY DOES WHOLE LIVING SYSTEMS COLLECT AND USE YOUR PERSONAL INFORMATION?

Whole Living Systems collects personal information reasonably necessary to carry out our business, and provide our services to you. We may also credit card information from you to facilitate payment for any of our services.

The purposes for which Whole Living Systems usually collects and uses personal information depends on the nature of your interaction with us, but may include:

  • registration purposes;
  • managing and improving the Website
  • to process and obtain payment for our services
  • responding to requests for information and other general inquiries;
  • informing you of our activities, events, facilities and services;
  • recruitment processes; and
  • responding to enquires and complaints.
  • In addition, some of your personal information may be used for other business purposes. Examples of the types of uses are set out below:
  • to comply with any requirement of any applicable statute, regulation, rule and/or good practice, whether originating from Australia or elsewhere;
  • to prevent or detect abuse of our services or any of our rights (and attempts to do so), and to enforce or apply our Privacy Policy and/or any other agreement and to protect our (or others') property or rights;
  • if instructed to do so by you or where you give us your consent to the use and/or processing involved;
  • to bring to your attention (in person or by post, email or telephone) information about additional services offered by us and/or our global affiliate, which may be of interest to you, unless you indicate at any time that you do not wish us to do so; and

Whole Living Systems generally collects personal information directly from you.  We may collect and update your personal information over the phone, by email, over the internet or social media, or in person.

In some cases it will be lawful for us to collect and use your personal information, for example where it is necessary as part of our, or a third party’s, statutory or public functions or because the law permits or requires us to.

HOW DOES WHOLE LIVING SYSTEMS INTERACT WITH YOU VIA THE INTERNET?

You may visit our Website without identifying yourself.  If you identify yourself (for example, by providing your contact details in your dealings with us, any personal information you provide to Whole Living Systems will be managed in accordance with this Privacy Policy.

Whole Living Systems’ website may contain links to third-party websites. Whole Living Systems is not responsible for the content or privacy practices of any websites that are linked to our Website.

CAN YOU DEAL WITH WHOLE LIVING SYSTEMS ANONYMOUSLY?

Whole Living Systems will provide you with the opportunity of remaining anonymous or using a pseudonym in your dealings with us where it is lawful and practicable (for example, when making a general enquiry).  Generally it is not practicable for Whole Living Systems to deal with you anonymously or pseudonymously on an ongoing basis.  If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

HOW DOES WHOLE LIVING SYSTEMS HOLD INFORMATION?

Whole Living Systems stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia and overseas).  Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

 

Whole Living Systems maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

Our Website may, but does not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our website are encouraged to exercise care in sending personal information via the internet. If you register online, we use 128-bit encryption when we ask for or you provide Personal Information or other confidential information. Also, some personal data, such as your membership id and/or password will be stored in encrypted form.

You should never reveal your password to third parties.

HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT BY WHOLE LIVING SYSTEMS

We will only keep the personal information we collect about you for as long as is necessary for the purposes set out in this Privacy Policy or as required to comply with any legal obligations to which we are subject.  The retention periods we apply take account of:

  • legal and regulatory requirements and guidance;
  • limitation periods that apply in respect of taking legal action;
  • our ability to defend ourselves against legal claims and complaints;
  • good practice; and
  • the operational requirements of our business.

We take steps to destroy or de-identify information that we no longer require or as required by an applicable law.

DOES WHOLE LIVING SYSTEMS USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?

Whole Living Systems may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you or as otherwise permitted under applicable privacy laws.

This means under certain privacy laws we do not always need your consent to send you marketing communications. However, where consent is required under applicable privacy laws, we will ask for this consent separately and clearly.  If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below or using the opt-out functionality contained in the electronic message.

If you opt-out of receiving marketing material from us, Whole Living Systems may still contact you in relation to its ongoing relationship with you.

HOW DOES WHOLE LIVING SYSTEMS USE AND DISCLOSE PERSONAL INFORMATION?

Use and disclosure for administration and management

We may engage third parties to undertake some of our Services or related services such as hosting, archiving, data security, payment services and e-mail communications. We may provide those third parties with access to and use of your Personal Information for the sole purpose of them providing their services to us. We will use reasonable endeavours to ensure that those third parties only use your Personal Information for the specific purposes for which it is provided to them and consistently with this Privacy Policy.

Whole Living Systems will also use and disclose personal information for a range of administrative, management and operational purposes.  This includes responding to enquiries and complaints regarding our services;

Other uses and disclosures

We may use and disclose your personal information for other purposes explained at the time of collection (such as in a specific privacy collection statement or notice) or otherwise as set out in this Privacy Policy.

Non Personal Information

We operate statistics gathering software on the website to collect information about the number of visitors coming to the Website. Usage data will be collected and correlated between your logged in and logged out sessions. No identifying information is collected by this software. We use this information to improve our own technical structure and performance and to determine which areas of the website are most popular.

From time to time, we may sell or disclose information you provide to us that is not Personal Information (and does not disclose your identity) to any person for any purpose at our sole discretion, including to people or companies located outside Australia. For example, we may sell, disclose or use information you provide to us that is not Personal Information to:

  • determine what advertising, promotional materials, products or services are likely to be of most interest to you or other website users and visitors; and
  • assist third parties to monitor general consumer trends in various areas.

We may also modify your Personal Information (through encryption or other de-identifying techniques) so that it is in a form from which you cannot be identified and sell or disclose such modified information to any person for any purpose, including to people or companies located outside Australia.

‘Cookies’

‘Cookies’ are small data files sent by a website and stored on your computer’s hard drive when you visit a website. A cookie can contain certain information that the website uses to track the pages you have visited. The only Personal Information a cookie can contain is information you personally supply. A cookie cannot read data off your hard disk or read cookie files created by other websites.

We may use cookies to identify information about your web browser session and personalisation data each time you use the Platform Services. Cookies can be used to enhance your use of the Website, as we use them to help personalise our delivery of our services to you, such as information that is most relevant to your location, activities and interests.

Our intention is to use cookies to manage individual sessions relating to the use of the Website and for providing data regarding visitors to our website.

You can set up your browser so that it does not accept our cookies. You can also manually delete our cookies from your browser. However, these actions may stop you from accessing the full benefit of our services.

Payment card information

We engage secure third party payment service providers identified on the Website from time to time to process payments for Platform Services offered through the website. Payments may be made by credit or debit cards as permitted by the website from time to time. We will not keep a record of your credit or debit card number for payments for Platform Services made via the secure third party payment service providers used by the website.

DOES WHOLE LIVING SYSTEMS DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?

We generally collect personal information about you in Australia or the jurisdiction in which the Whole Living Systems affiliate you are dealing with is located. Personal Information we collect from you is stored securely on servers in Australia. We also engage a third party data hosting service provider (“Hosting Service Provider”) to provide data hosting services and store data.

Servers in which your information (including your Personal Information) is stored by our Hosting Service Provider are currently located in Australia, although additional or other locations may be used in the future. In particular, our Hosting Service Provider will also likely store your Personal Information on servers located in the United States or elsewhere. The Hosting Service Provider may be subject to foreign laws in those locations that do not have privacy obligations similar to the Act and/or that compel disclosure of personal information to third parties, such as governmental authorities.

We only ever disclose your personal information outside the jurisdiction it was collected where we are permitted to do so under applicable privacy laws. Generally this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws.

There are circumstances where we may disclose your personal information to an overseas recipient. You have provided your consent or we are otherwise permitted to do so under the Australian Privacy Principles or other relevant laws.

HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?

You are entitled to access your personal information held by Whole Living Systems on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?

You may contact Whole Living Systems at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly.  We may ask you to provide further information about your complaint and the outcome you are seeking.  We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint.  If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that Whole Living Systems may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner.  The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

HOW CHANGES ARE MADE TO THIS PRIVACY POLICY?

Whole Living Systems may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes. We also try to let you know about major changes to our Privacy Policy (for example by putting a notice up on our website).

HOW CAN YOU CONTACT Whole Living Systems?

The contact details for Whole Living Systems are:

 

Whole Living Systems Privacy Officer: info@weareloup.com

 

This Privacy Policy was last updated in October 2018.