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PRIVACY POLICY

Making Strides Pty Ltd
Privacy policy

 

1 Introduction 

Making Strides Pty Ltd (Making Strides) respects the privacy of our patients, carers, staff, and others involved with our company. 

This policy sets out how we collect, handle and use personal information about you. 

We are subject to the privacy laws in Australia, being the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). 

1.1 Definitions 

In this policy, some words have special meaning. Those words and the corresponding meaning are as follows: 

Making Strides, we, us, our means Making Strides Pty Ltd ACN 165 965 917, its associates (as that term is defined and used in the Corporations Act 2001 (Cth)). 

Personal information means information or an opinion about an identified natural person, or a natural person who is reasonably identifiable. 

Privacy Act means the Privacy Act 1988 (Cth). 

Services means those services provided to any person by Making Strides in relation to exercise physiology and support services. 

Website means the website of Making Strides. 

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2 How we collect your Personal Information 

2.1 How, what and why we collect your Personal Information 

We collect the following information about you (which is included but not limited to the information set out in the table below) that: 

(a) you give us directly – _when you deal directly with us for the provision of the Services. We refer to this information as Services Information; 

(b) we receive from other sources – _which may include: 

(i) information we receive from other business partners, clinicians, sub-contractors, advertising networks, analytics providers, search information providers; 

(ii) information we receive from your appointed medical practitioner, the National Disability Insurance Scheme and support persons, including clinicians and carers; 96512 

(iii) information we receive from software you utilise and provide us with access to, or software we utilise and provide you with access to; 

(iv) information about you from publicly available sources including, Court judgments, directorship and bankruptcy searches, Australian Post, White Pages directory or social media platforms (such as LinkedIn, Facebook, Twitter, Google, Instagram etc); and 

(v) information we receive from payment providers or merchants. 

We refer to this information as Third Party Information. 

 

(c) we collect about you and your device – _which may include: 

(i) technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in and versions, cookies, operating system, platform and type of device; and 

(ii) information collected from you, as you browse our website about the individual web pages or products that you view, what websites or search terms referred you to the website, and information about how you interact with the website. 

We refer to this automatically collected information as Device Information.

(d) you give us directly as a result of being employed by us – _which may include: 

(i) medical records and/or information pertaining to existing medical conditions we require in order to provide the Services and/or are required to hold in case of an emergency to assist you; and 

(ii) results of any tests we are required to undertake. 

We refer to this as Sensitive Information. 

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We collect Device Information using the following technologies: 

(a) “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, see clause 1.8 of this policy and/or visit http://www.allaboutcookies.org; 

(i) “Log files” track actions occurring on the store, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps; and 

(ii) “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Store.

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Information we may collect:

Services Information, which may include: 

  • name; 

  • medical information; 

  • Government identifiers; 

  • details of support persons; 

  • company name; 

  • residency; 

  • date of birth; 

  • country of residence; 

  • job title and employer; 

  • Tax File Number; 

  • Employee record information; 

  • CV, resume or application related behaviour 

  • contact details such as address, email address; 

  • business/mailing address; 

  • title; 

  • nature of business; 

  • bank account and credit or debit card details; 

  • medical advisors; 

  • advice received from the client or prospective client that may contain additional personal information, such as family relationships and other business-related connections; 

  • qualifications, memberships and other accreditations; 

  • verification of identify documents; 

  • memberships or associations; 

  • racial or ethnic background, political or religious beliefs; and 

  • online interactions with our website, publications, alerts and social media activity. 

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Reasons we might collect this information:

Exercise Physiology and Support Services 

  • to provide you with the Services; 

  • to maintain a database of participants; 

  • to employ you; 

General 

  • to identify you and conduct appropriate identity checks; 

  • to communicate with you; 

  • to send you relevant news and marketing materials; 

  • to respond to your requests, questions, comments and complaints; 

  • to the extent we consider it necessary to provide the Services to you, or to improve the Services and business activities we undertake; 

  • to publish your reviews, forum posts or other content on our Website; 

  • to improve or optimise our Services; and 

  • any other reason allowed at law. 

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Third Party Information:

  • to provide you with the Services; 

  • to employ you; 

  • to identify you and conduct appropriate identity checks; 

  • to communicate with you; 

  • to communicate about and provide you with our current and future products and services; 

  • to send you relevant news, promotion and marketing materials, either initiated by us or a third party; 

  • to respond to your requests, questions, comments and complaints; or 

  • to the extent that we consider it is necessary to provide the Services to you or to improve the Services and business activities that we undertake; 

  • to publish your reviews, forum posts or other content on our Website (or other website operated by us); 

  • to improve and optimise the Services; and 

  • any other reason allowed at law. 

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Device Information: 

  • to help us screen for potential risk and fraud; 

  • improve and optimise our Website (for example, by generating analytics about how our customers browse and interact with the Website, and to assess the success of our marketing and advertising campaigns); 

  • to provide you with local information and alerts about our products and services; 

  • to improve our website, goods and services; 

  • to comply with local legal restrictions; 

  • to gather anonymous statistics; 

  • for analytical purposes; 

  • to ensure proper function of the Website and our software; or 

  • any other reason allowed at law. 

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Sensitive Information: 

  • to provide you with the Services; 

  • to employ you; 

  • to assist you in a medical emergency; 

  • to create a safe workplace for you and for others in accordance with our obligations under the Work Health and Safety Act (Qld) 2011; and 

  • any other reason required by law. 

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Video footage and audio: 

  • for internal training and quality purposes; 

  • for promotional materials, including use on social media and / or the internet; 

  • to ensure effective delivery of the Services; 

  • any other reason allowed at law. 

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Information, communication or opinions about any of our products, services, transactions, payment history or business activities. :

  • to improve the products, services and business activities that we undertake; or 

  • any other reason allowed at law. 

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Information that may be collected by us or on our behalf via third parties including the date and time of your visit to our website, IP address, documents and pages you access, type of browser and setting, operating system, address of a recurring site you are about to visit; information you submit regarding payment particulars, device identifier, including UDID, device details, pages visited, language selections, cookies, tracking pixels, geographic area and location. :

  • to provide you with local information and alerts about the Services; 

  • to improve our website and services; 

  • to comply with local legal restrictions; 

  • to gather anonymous statistics; 

  • for analytical purposes; 

  • to ensure proper function of the website and online software; or 

  • any other reason allowed at law. 

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Identifiers, which may include: [ business number, citizenship and residency details, details regarding and information provided by your referees, details regarding and information provided by your guarantor(s) and business partner(s), financials/credit/criminal history checks, employment history, education history; or identity documents. ]

  • to employ you; 

  • to identify any guarantor(s); 

  • to conduct identity and criminal checks; 

  • to conduct credit checks; or 

  • any other reason allowed at law. 

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Other information:

  • to provide you with the Services and to undertake business activities; 

  • as described to you at the point of collection; or 

  • any other reason allowed at law. 

If we receive identifiable information from a third party, we will take reasonable steps to ensure that you have given express or implied consent to the collection of that information. If it is determined that we are unable to have possession of the information under a relevant law, we will destroy the information or ensure that the information is de-identified. 

In some situations, you will have the option to deal with us anonymously or through a pseudonym, however, where you are requesting the Services and/or employment with or from us, it may become impracticable to provide those services to you without verifying your identity. Where you fail to provide us information or where the information provided is incomplete and/or inaccurate, or you choose not to provide us with the information that we have requested, it may affect our ability to provide you with our products and services 

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2.2 Tax File Number 

We will handle your tax file number in accordance with the Privacy (Tax File Number) Rule 2015 (Cth). 

2.3 Do Not Track Settings 

Please note that we do not alter our Website’s data collection and use practices when we see a “Do Not Track” signal from your browser. 

2.4 Behavioural Advertising 

(a) As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. 

(b) You can opt out of targeted advertising by using the links below: 

(i) Facebook: https://www.facebook.com/settings/?tab=ads 

(ii) Google: https://www.google.com/settings/ads/anonymous 

(iii) Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads 

(c) Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. 

2.5 Website analytics 

(a) To improve your experience on our Website, we may use “cookies”. Cookies are an industry standard and most major websites use them. A cookie is a small text file that our Website may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of our Website. 

(b) Our Website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites. When you go to other websites, we advise you to be aware and read their privacy policy. 

(c) Our Website uses Google and Wix Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. 

(d) By using our Website, you consent to the processing of data about you by Google in the manner described in Google's Privacy Policy and for the purposes set out in this policy. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google. 

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3 Disclosure of Personal Information 

3.1 Primary purpose 

(a) We will collect and use the Personal Information for the primary purposes as provided in Section 2 of this policy. 

(b) The secondary purpose in which we will use your Personal Information, includes (but is not limited to): 

(i) facilitating our internal business processes; 

(ii) communicating with clients, prospective clients, and other external parties; 

(iii) providing ongoing marketing information about the Services; 

(iv) complying with our legal obligations; and 

(v) dealing with enquiries and complaints. 

3.2 Secondary purpose 

We may share your information with: 

(a) any of our associates; 

(b) third parties, including: 

(i) clinicians employed by us or contracted to us; 

(ii) carers of participants; 

(iii) payment providers; 

(iv) software providers; 

(v) business partners, agents, suppliers and subcontractors; 

(vi) regulators, including Commonwealth and State Governments and Departments; 

(vii) National Insurance Disability Scheme; 

(c) any prospective buyer of any part of our business or assets; or 

(d) where we are required to disclose your information to comply with any legal obligation, or to enforce any agreements; or to protect the rights, property, or safety of us and our customers, or others. This includes, where relevant, exchanging information with organisations for the purposes of fraud protection and credit risk reduction. 

3.3 Sharing your personal information 

(a) We share your Personal Information with third parties to help us use your Personal Information and provide the Services and / or employ you. Specifically, we share your Personal Information with the following service providers: 

(i) We use the following bookkeeping and accounting services to provide the Services and you can read the privacy policies of those providers at the below links: Xero - https://www.xero.com/au/about/legal/privacy/. 

(ii) We use Cliniko as our practice management system to provide you the Services and you can read the privacy policy of Cliniko at https://www.cliniko.com/policies/privacy/. 

(iii) We use Google Analytics to help us understand how our customers use the Website – you can read more about how Google uses your Personal Information here: https://policies.google.com/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. 

(iv) We use Facebook Pixel as an analytics tool to help us understand how our customers use the Website and to determine how effective our advertisements on Facebook and Instagram are – you can read about how Facebook uses your Personal Information here: https://www.facebook.com/privacy/explanation. 

(v) We use Wix.com Ltd to host our website and use the Wix Analytics to help use understand how our customers use the Website, you can read the privacy policy of Wix here: https://www.wix.com/about/privacy. 

(vi) We use Dropbox to store client files, staff meeting notes, practicum student information and relevant client and staff information, to read the privacy policy of Dropbox, see here: https://www.dropbox.com/privacy. 

(b) We will not share your Sensitive Information unless required by law or in an emergency. When you are no longer employed by us, we will delete and remove your Sensitive Information, except to any extent that we are required by law to retain. 

(c) Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. 

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4 Storing your Personal Information 

4.1 Storing your information 

(a) In order to offer the Services or to employ you, we may store and manage data electronically or in paper form. 

(b) Where data is stored electronically, it is done so on cloud-based services with the services providers disclosed in point 3.3 above. Please see each service providers’ privacy policy for confirmation of which jurisdictions in which your data will be held. At the date of this policy, Making Strides understand this includes: 

(i) Australia; 

(ii) United States of America; 

(iii) Israel; 

(iv) Germany; and 

(v) Japan. 

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(c) We will take all steps reasonably necessary to ensure that your Personal Information is handled in accordance with the Australian Privacy Principles and this policy. Despite our endeavours, the transmission of information through the internet is not completely secure. 

(d) Submission of any information to us is an acknowledgement that you agree to such use, storage and disclosure. 

4.2 Security of your Personal Information 

We take the storage and handling of your Personal Information seriously. To secure your Personal Information, we have engaged external cyber security consultants to regularly audit and monitor our processes and staff access of Personal Information. 

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5 Accessing and correcting your Personal Information 

(a) You may request access to or correct Personal Information that we hold about you at any time by contacting our Privacy Officer using the details set out in this policy. We will respond to any such request for access to Personal Information within a reasonable timeframe and will provide you access to the Personal Information that we hold pertaining to you, unless we are authorised not to do so by law. 

(b) We may charge you a reasonable fee for processing your request to access your Personal Information and should we decline you access to your Personal Information, a written explanation will be provided setting out the legal reasoning for doing so. 

(c) If upon receiving your Personal Information, or at any other time, you believe the Personal Information that we hold about you is incorrect, out of date, incomplete, irrelevant or misleading, please notify our Privacy Officer using the details set out in this policy. 

(d) If we decline to correct your Personal Information as requested by you, a reason for refusal will be provided except to the extent that it is unreasonable to do so. In the event that we decline the request to correct Personal Information, you may request to associate a statement with the information. 

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6 Complaints 

(a) If you believe we have not fulfilled our obligations under any relevant law or have not complied with the terms of this policy or would like to appeal a decision made by us in relation to your Personal Information, you can make a complaint in writing to our Privacy Officer using the contact details set out in this policy. 

(b) We will respond to you within a reasonable period of time (or where a period is specified by any law, that period) to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint. 

(c) If after getting our response you are still not satisfied that your complaint has been resolved or adequately 

Officer of the Australian Information Commissioner (OAIC) 

Phone: 1300 363 992 

Email: enquiries@oaic.gov.au 

GPO Box 5218, Sydney, NSW 2001 

See the OAIC website for further details: www.oaic.gov.au 

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7 Contact 

If you have any comments, concerns or questions regarding this policy or Personal Information that we hold about you, please contact our Privacy Officer: 

Privacy Officer Making Strides Email: info@makingstrides.com.au 2/7 Dover Drive, Burleigh Heads, Qld, 4220 

We reserve the right to update this policy at any time without notice. 

Any changes will be published on our Website. 

Last revised and updated on 8 April 2021. 

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