Privacy Policy
1 INTRODUCTION
This document sets out the privacy policy of Maindok, Estelle trading as Soulavita ABN 11 945 805 161 (referred to in this privacy policy as ‘we’, ‘us’, or ‘our’). For the purposes of applicable data protection law, (in particular, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and the UK Data Protection Act 2018), your data will be controlled by us.
This privacy policy applies whenever we collect your personal information and/or personal data (your personal data). This includes between you, the visitor to this website (whether directly as our customer or as personnel of our customer), and us, the owner and provider of this website and also where we are directed by a third party to process your personal data. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of the website and the provision of our services to you.
We take our privacy obligations seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
2 TYPES OF PERSONAL INFORMATION WE COLLECT
The personal data 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 as set out below;
(j) information about your business or personal circumstances;
(k) information in connection with any client surveys, questionnaires and promotions you participate in;
(l) when we use analytical cookies, 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 this website, in the course of us providing services to you, or otherwise required by us or provided by you.
3 HOW PERSONAL INFORMATION IS COLLECTED
We will collect your personal information in a lawful and fair way. We will only collect your personal information where you have consented to it, or otherwise in accordance with the law.
How we collect information from you
We may collect personal information where you:
(a) contact us through our website;
(b) receive goods or services from us;
(c) submit any of our online inquiry forms;
(d) communicate with us via email, telephone, SMS, social applications (such as LinkedIn or Facebook) or otherwise;
(e) interact with our website, social applications, services, content and advertising; and
(f) invest in our business or enquire as to a potential purchase in our business.
How we collect information from third parties
Where possible, we collect your personal information directly from you. However, there may be occasions when we collect personal information (including sensitive information) about you from someone else.
How you provide information for someone else
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.
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.
How we collect information from cookies
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.
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.
4 USE OF YOUR PERSONAL INFORMATION
We collect and use personal data for the following primary purposes:
(a) to provide goods, services or information to you;
(b) for record keeping and administrative purposes;
(c) to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing goods or services to you;
(d) to improve and optimise our service offering and customer experience;
(e) to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
(f) to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
(g) to consider an application of employment from you.
We may also use your personal information for:
(h) secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use;
(i) such purposes where we reasonably believe that use of your personal information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
(j) any other purpose for which we receive consent from you; or
(k) any other purpose which is permitted or required under applicable privacy laws.
5 SHARING YOUR DATA
We respect your privacy, and we will take reasonable steps to keep your personal information confidential and protected. We may share your personal data in certain circumstances, as follows:
(a) where there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal data and non-personal data contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances;
(b) our professional advisors such as lawyers, accountants and auditors;
(c) our related entities; or
(d) any third parties you have consented personal information to be disclosed to.
We may also disclose personal information to third party contractors as required for us to provide our goods and services to you, such as cloud-service providers, IT professionals, marketing agencies and debt collection agencies.
We take care to work with such third parties who we believe maintain an acceptable standard of data security and require them not to use your personal information for any purpose except for those activities we have asked them to perform on our behalf.
We will not otherwise disclose your personal information unless:
(e) you have consented to us disclosing your personal information for particular circumstances;
(f) as needed in an emergency or in investigation suspected criminal activity;
(g) we are required to disclose under a subpoena, court order or other mandatory reporting requirements;
(h) we reasonably believe that disclosure of your information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
(i) it is reasonably necessary for the establishment, exercise or defence of a legal claim; or
(j) it is otherwise authorised or required by law.
6 STORAGE OF YOUR PERSONAL INFORMATION
All personal information we collect is stored on servers located in Australia and, for the most part, we do not disclose or transfer personal information overseas.
However, the cloud service providers we engage to provide us Australian-based servers may operate overseas disaster recovery sites or have personnel overseas who may access the personal information we hold to assist us in managing our servers.
We also may use Google Analytics to track web traffic information which is operated by Google which stores information across multiple countries.
When you communicate with us through a social media service such as Facebook or Twitter, the social media provider and its partners may collect and hold your personal information overseas.
7 SENSITIVE INFORMATION
Collection of sensitive information
We may collect sensitive information about you during the course of providing you our goods and services. We will only collect this sensitive information where you consent to such collection and either directly provide us with this information or it is provided by a referring health care provider.
Types of sensitive information we collect
The sensitive information we collect may include the following:
(a) health information, history and reports, including (but not limited to) operation history, broken bones, accident and injury history, medication history, pregnancy status;
(b) referring health care provider and associated referral letters;
(c) private health fund and private health insurance cover details;
(d) Medicare number, healthcare identifiers or concession card or other entitlement details; and
(e) any other sensitive information provided by you or a third party to us via our website or platforms, or otherwise provided by you or a third party to us.
How we use your sensitive information
Your sensitive information will only be used for the purpose of:
(f) providing you with our goods and services;
(g) complying with our legal obligations, resolving disputes or enforcing our agreements with you;
(h) sending you messages, reminders, notices, updates, security alerts, and other information requested by you; or
(i) any other purpose which is permitted or required under applicable privacy laws.
How we disclose your sensitive information
Your sensitive information will only be disclosed to third parties where permitted or required under applicable privacy laws.
How you can withdraw consent
If you wish to withdraw your consent to our collection, use or disclosure of your sensitive information, please contact us using the contact details set out below. We will deal with all such requests within a reasonable timeframe.
8 SECURITY
We take reasonable steps to ensure your personal data 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 data.
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 YOUR RIGHTS
You have various rights with respect to our use of your personal data:
(a) Access: You have the right to obtain access to your information (if we’re processing it) and certain other information (similar to that provided in this privacy notice). This is so that you’re aware and can check that we’re using your information in accordance with data protection law.
(b) Be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this privacy policy.
(c) Rectification: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using our contact form to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
(d) Objecting: You also have the right to object to processing of your personal data in certain circumstances, including processing for direct marketing.
(e) Restricting: You have the right to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further.
(f) Erasure: You have the right to ask us to erase your personal data when the personal data is no longer necessary for the purposes for which it was collected, or when, among other things, your personal data have been unlawfully processed.
(g) Portability: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
(h) Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority. In the UK, the supervisory authority is the Information Commissioner’s Office.
(i) Withdraw consent: If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time. This includes your right to withdraw consent to us using your personal data for marketing purposes.
You may, at any time, exercise any of the above rights, by contacting our email address provided below.
11 HOW LONG WE KEEP DATA
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will securely destroy your personal data in accordance with applicable laws and regulations.
If you would like further information about our specific retention periods for your personal data, please contact us using our email address provided below.
12 TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA (‘EEA’)
To provide our services, we may transfer the personal data we collect to countries outside of the UK or EEA which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection.
When we do this, we will make sure that it is protected to the same extent as in the EEA and UK as we will put in place appropriate safeguards to protect your personal data, which may include standard contractual clauses.
For more information, please contact us at our email address provided below.
13 CONTACT US
For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using the details set out below:
Email: wellness@soulavita.com
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. Where we make any significant changes, we will endeavour to notify you by email.