collected by us, offline or online, including through our mobile application, and our website located at ebtonline.com.au.
Personal information: The types of personal information we may collect about you include:
- your name;
- images of you;
- your contact details, including email address, mailing address, street address and/or telephone number;
- your age and/or date of birth;
- your credit card or payment details (through our third-party payment processor);
- your preferences and/or opinions;
- information you provide to us through customer surveys;
- information you provide to use in our health assessment questionnaire;
- your sensitive information as set out below;
- details of products and services we have provided to you and/or that you have enquired about, and our response to you;
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
- information about your access and use of our Platform, including through the use of Internet cookies, your communications with our Platform, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
- additional personal information that you provide to us, directly or indirectly, through your use of our Platform, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
- any other personal information requested by us and/or provided by you or a third party.
We may collect these types of personal information directly from you or from third parties, such as social media platforms or your healthcare providers (including your GP, with your consent).
COLLECTION AND USE OF PERSONAL INFORMATION
We may collect, hold, use and disclose personal information for the following purposes:
- to enable you to access and use our Platform, associated applications and associated social media platforms;
- verifying your identity;
- maintaining your user account on the Platform;
- managing client referrals;
- to contact and communicate with you;
- for internal record keeping and administrative, invoicing and billing purposes;
- for analytics, market research and business development, including to operate and improve our Platform, associated applications and associated social media platforms;
- to run competitions and/or offer additional benefits to you;
- for advertising and marketing, including to send you promotional information about our products and
- services and information about third parties that we consider may be of interest to you;
- to comply with our legal obligations and resolve any disputes that we may have; and
- if you have applied for employment with us; to consider your employment application.
We will only process your personal information for our legitimate interest if we receive any requests, or we must perform a service in relation to, for example, any of our products or services. We use your personal information to fulfil your request or perform or provide you with our product or service. Where we need to fulfil your order, or manage your account, we will
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may disclose personal information to:
- third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
- our employees, contractors and/or related entities;
- our existing or potential agents or business partners;
- sponsors or promoters of any competition we run;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia; and
- third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia.
If you are a resident of the European Union, upon written request, we may provide you with a list of the third parties we use to process your personal information.
The countries to which we send data for the purposes listed above may not have the same data protection laws as the
Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act and if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.
HOW WE TREAT PERSONAL INFORMATION THAT IS ALSO SENSITIVE INFORMATION
Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information.
We will primarily collect sensitive information from you when you complete our health assessment questionnaire. The type of sensitive information we may collect about you includes:
- height and weight;
- personal medical history;
- use of medication;
- food and nutritional consumption; and
- allergies and food preferences.
We will not collect sensitive information about you without first obtaining your consent.
Provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected, including formulating custom meal plans and personalised nutrition information for you.
Sensitive information may also be used or disclosed if required or authorised by law.
OUR COMMITMENT TO YOU
Your personal information will be:
- be processed lawfully, fairly and in a transparent manner by us;
- only be collected for the specific purposes we have identified in the ‘collection and use of personal information’ clause above and personal information will not be further processed in a manner that is incompatible with the purposes we have identified;
- be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal information is processed;
- be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information);
- be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal information was collected;
- be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.
We will only retain your personal information 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.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see ‘access, erasure and data portability’ below for further information.
In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.
YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this Platform or the products and/or services offered on or through it.
Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Unsubscribing: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Objecting to processing: You have the right to object to processing of your personal data that is based on our legitimate interests. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal information.
Access, erasure and data portability: If you are a resident of the European Union, you may have the right to request details of the personal information we hold about you, or to request that we erase the personal information we hold about you, or that we transfer this information to a third party.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact the Office of the Australian Information Commissioner if you wish to make a complaint and you may also have the right to make a complaint to the relevant authority in the country in which you are based.
STORAGE AND SECURITY
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as the pseudonymisation and encryption of personal information, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
COOKIES AND WEB BEACONS
We may use web beacons on our Platform from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.
LINKS TO OTHER WEBSITES
For any questions or notices, please contact our Privacy Officer at: