EFFECTIVE DATE: JANUARY 2019
1. Be You Be Free Ltd ACN 616648367 ("Be You Be Free we, and us") is committed to protecting the information about you that we collect, store and use when you provide it to us at our web: http://www.beyoubefree.com.au (Website). We manage your information in accordance with the requirements of the Australian Privacy Principles (APPs) and the Privacy Act 1988 (Cth) which govern how organisations collect, hold, use and disclose personal information. The APPs also give individuals a right to know what information an organisation holds about him or her, and a right to correct it if it is wrong. This document describes how we manage any personal information we have collected about you from the Website.
PERSONAL INFORMATION COLLECTION AND USE
3. Be You Be Free does not collect personally identifiable information about individuals except when such individuals specifically provide such information on a voluntary basis.
4. When you visit our Website or attend our classes, you may be asked to complete an online form to submit information about you to us, a pre-training questionnaire or a wellness questionnaire. Such information may include:
4.1 your name;
4.2 details relating to your health and medical history, including but not limited to pre-existing conditions and;
4.3 your contact details such as your telephone number, physical address and email address; and
4.4 information that allows us to process your payment to us, such as bank account details and credit card information.
WHAT WE DO WITH YOUR PERSONAL INFORMATION
5. We collect, hold and use your personal information for a number of purposes, generally, we use the information that we collect to:
5.1 assist us in providing services to you;
5.2 contact you or respond to your queries;
5.3 display, update and maintain the content of the Website;
5.4 tailor your experience of the Website and our communications to you; and
5.5 send information about product launches and promotions, regular email communications or newsletters outlining news, services or events.
6. We may use the information that we collect from you:
6.1 to advertise our services and the Website;
6.2 for our internal administrative, marketing and planning requirements;
6.3 to compile and report statistics, with all the relevant personal and/or proprietary information de-identified prior to the completion of such statistics; and
6.4 for purposes that are expressly permitted under any agreement with you.
TO WHOM WILL BE YOU BE FREE DISCLOSE MY PERSONAL INFORMATION?
7. We do not disclose contact information about you publicly or to other third parties by us unless it is authorised or required by law (or when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on us in relation to the Website) or as otherwise outlined in this policy.
8. From time to time, we will also disclose your personal information (on a confidential basis) to agents and others that we use in the ordinary operation of our business, such as PTminder (the software that we use to manage your bookings and billing), marketing and promotion, user experience research and surveys, website hosting and support and maintenance. We will only disclose your information to the extent required for the limited purpose of the third party providing services contracted to us so that we may service you.
9. If Be You Be Free is involved in a merger, acquisition, or sale of all or a portion of its assets, your personal information or other information may be part of the transferred assets.
10. We may also disclose aggregated data (in a form that does not identify you individually) to our advisors for the purposes of conducting market and user experience analysis.
11. While we store the majority of the personal information that we collect from you in Australia, we may from time to time store some of the information in computer servers located in the United States. We will take such reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles.
12. We may from time to time publish customer testimonials on our Website, in social media profiles, on our Youtube channel and within advertising creative material. These testimonials may contain personally identifiable information. We obtain your written consent at the time the testimonial is recorded. If you want your testimonial removed please contact us at firstname.lastname@example.org.
VIDEOS, PHOTOGRAPHS AND IMAGES
13. Be You Be Free may occasionally take videos, photographs/ images of the sessions, including participants. We’ll try our best to get your consent beforehand but this may not always be possible. We reserve the right to use these photographs/images for commercial purposes without payment to you. These images may be used in our marketing including but not limited to our facebook page and advertisements, printed flyers, and our website.
MANNER OF COLLECTION
14. We will use reasonable endeavours to only collect information directly from you. If you are disclosing details of another person (for example, where you are subscribing on their behalf), it is your sole responsibility to ensure that that person understands and consents to the collection, use and disclosure of their personal information in the manner set out in this policy.
WEBSITE USER EXPERIENCE TRACKING
15. We may use Google Analytics Advertising products: Remarketing with Google Analytics and Google Analytics Demographics and Interest Reporting. Google Analytics collects data about our site traffic via Google Advertising cookies and anonymous identifiers. Data collected via these Google products is not linked with any personally identifiable information you submit while on our Website. If you wish to opt out of the Google Analytics data collection, you may do so on Google's website at https://tools.google.com/dlpage/gaoptout/.
16. As is true of most website and mobile applications, we and, in some instances, our third party tracking-utility partners gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
17. We use this information, which does not identify individual users, to analyse trends, to administer the Website, to track users' movements around the Website and to gather demographic information about our user base as a whole.
18. Technologies such as: cookies, beacons, tags and scripts are used by Be You Be Free and our partners (marketing and development partners), affiliates, or analytics or service providers (online customer support provider, email marketing system). These technologies are used in analysing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
20. We may use local storage objects (LSOs) such as HTML5 to store content information and preferences.
21. Third Parties, with whom we partner to provide certain features on our site or to display advertising based upon your web browsing activity, use LSOs such as HTML5 to collect and store information.
SOCIAL MEDIA FEATURES
23. We may use your personal information to provide you with material, promotions and communications from time to time about services and products available to you from us, or from other service providers in partnership with us, or to invite you to continue to use our services. This information will only come from us. We will not on-sell your personal information to other providers without your consent.
24. You may opt out of receiving promotional materials from us at any time by contacting us at email@example.com or by following the 'unsubscribe' link on the relevant promotional emails.
PROTECTING AND MAINTAINING PERSONAL INFORMATION
25. We will take all reasonable steps to protect the information we hold about you from unauthorised access, use and disclosure, however we cannot guarantee that our systems and stored data will be completely free from third party interception or are free from corruption.
26. Certain parts of the Website (such as those parts that require you to provide us with your credit card number) provides the ability for you to transmit information to our Website in an encrypted form by using secure socket layer technology (SSL). However, other parts of the Website are not protected by any form of encryption to protect information you send from your computer to us over the Internet. Further, no method of transmission over the Internet, or method of electronic storage, is 100% secure. In light of this, we cannot ensure or warrant, and do not warrant, the security or privacy of your personal information, including payment and account details. You transmit this information at your own risk. If you have any questions regarding security you can contact us at firstname.lastname@example.org
27. If you use our Website to link to another site we encourage you to view their terms and conditions of use, privacy policies and security statements before disclosing any of your personal information on those sites.
ACCESSING PERSONAL INFORMATION
28. It is your responsibility to advise us of any changes to your personal details to ensure we can keep our records accurate and up to date. If you wish to access the information we hold about you, please submit a request to email@example.com. If you believe that the personal information we hold about you is incorrect, you are entitled to request amendment of such information. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it. You may also request that we delete the personal information that we hold about you. Please note that if we delete your contact information, we may not be able to provide you with the subscribed service.
29. If you request us not to use personal information in a particular manner or at all, we will adopt reasonable measures to observe your request but we may, to the extent permitted by law, still use or disclose your information if you subsequently consent to the disclosure or we believe the use or disclosure is reasonably necessary to assist a law enforcement agency or as otherwise required or authorised by law. If you know the information we hold about you is not accurate or complete, please notify us. We will respond to requests for access within 30 days.
30. We will retain your information for as long as your subscription is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
IF YOU HAVE CONCERNS
31. If you have any concerns about how we handle your personal information or require further information, please contact the Privacy Officer at firstname.lastname@example.org. Also use this contact if you no longer consent to receiving marketing material from us, or to the posting of your personal information on the Website.
32. This document represents our policy as at November 2016. We may change this document from time to time to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a prominent notice on this Website prior to the change becoming effective. Although we intend to observe this policy at all times, it is not legally binding on us in any way. From time to time we may regard it as necessary or desirable to act outside the policy. We may do so, subject only to any statutory rights you have under the Privacy Act or other applicable legislation. We encourage you to regularly review this statement to inform yourself of any amendments.
Be You Be Free Pty Ltd