SOLE VITALITY PRIVACY POLICY
- INTRODUCTION
This privacy policy provides you with details of how Sole Vitality collects and processes your personal data through your use of our site www.solevitality.com.au.
As we are an online business trading globally we aim to comply with the Australian Privacy Principles and General Data Protection Regulations (GDPR) to ensure that your information is protected. By providing us with your data, you warrant to us that you are over the age of 18 years.
Sole Vitality is the controller of the personal information collected via this website and we are responsible for your personal data (referred to as “we”, “us” or “our” in this Privacy Policy). We use the information we collect about you to maximize the services that we provide to you. We respect the privacy and confidentiality of the information provided.
Contact Details
Our full contact details are: Sole Vitality Reflexology ABN – 88549591128. Sole Vitality is located in Victoria, Australia. Should you require a postal address for any reason please email solevitality@optusnet.com.au.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing solevitality@optusnet.com.au
2. PERSONAL INFORMATION – TYPE, PURPOSE AND LEGAL GROUNDS
Personal information/data means any information capable of identifying an individual. It does not include data that is anonymous in its source. We may process the following categories of personal data about you:
Communication Information
Communication information includes any communication that you send to us. This information can be sent to us through:
- the contact form on our website,
- free resources you have opted in to receive
- email marketing
- newsletters
- email, text, social media messaging
- social media posting or
- through any other communication that you send us.
We process this data for the purposes of:
- communicating with you,
- for record keeping and;
- operate our website and ensure relevant content is provided to you,
- to ensure the security of our website,
- to maintain backups of our website and/or databases and;
- to enable publication and administration of our website, other online services, and business.for the establishment, pursuance or defence of legal claims. Our legal ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.Our legal ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Information
Customer information or data includes any information you provide relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.
We process this information to:
- supply the goods and/or services you have purchased and;
- to keep records of such transactions.
Our legal ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Information/Data
User information includes data about how you use our website and any online services together with any data that you may post for publication on our website or through other online services. We process this data to:
- operate our website and ensure relevant content is provided to you,
- to ensure the security of our website,
- to maintain backups of our website and/or databases and;
- to enable publication and administration of our website, other online services, and business.
- Our legal ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical DataTechnical data is information about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our legal ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Information
Marketing information includes data about your preferences in receiving marketing from us and our third parties and your communication preferences.
We process this data to:
- enable you to receive our newsletter
- enable you to participate in our promotions such as competitions, prize draws and free giveaways,
- to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.
Our legal ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer, User, Technical and Marketing Information/Data to:
- deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and:
- measure or understand the effectiveness of the advertising we offer to you.
Our legal ground for this processing is legitimateinterest which is to grow our business.
We may also use such data to send other marketing communications to you and our legal grounds for doing so is either your consent or legitimate interest namely to grow our business. (Please see Marketing Communications below).
Sensitive Data
Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
We need to collect the following health information about you to provide reflexology services to you- name, email address, and details about your physical, emotional and mental health.
We require your explicit consent for processing sensitive data, so when you submit your details, we will ask you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected.
We do not collect any information about criminal convictions and offences.
We do not carry out automated decision making or any type of automated profiling.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
Contract Obligations
Where we are required to collect personal information by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you).
If you don’t provide us with the requested information, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
Use of Personal Information
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In the event we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal information without your knowledge or consent where this is required or permitted by law.
3. HOW YOUR PERSONAL INFORMATION IS COLLECTED
We may collect personal information about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails).
Cookies
We may automatically collect certain data from you as you use our website by using cookies and similar technologies.
A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analysetraffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. By not blocking cookies and continuing to browse you are authorisingthe use of cookies. If you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
How do we use cookies?
We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and/or services in response to what you might need or want. Types of Cookies:
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.
Cookies categories:
Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and/or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet. Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
Please note that third parties who advertise on our website (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
4. MARKETING COMMUNICATIONSOur lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests, namely to grow our business.
We may send you marketing communications from us if:
- you made a purchase or asked for information from us about our goods or services or
- you agreed to receive marketing communications and, in each case, you have not opted out of receiving such communications since.
- If you are a limited company, we may send you marketing emails without your consent. You may opt out of receiving marketing emails from us at any time.
Express consent
It is unlikely that Sole Vitality will share your personal data with any third party for their own marketing purposes, however, in such circumstances, we will obtain your express consent.
Stopping marketing messages
You can ask us or third parties to stop sending you marketing messages at any time by:
- by following the opt-out links on any marketing message sent to you or
- by emailing us at solevitality@optusnet.com.au at any time
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, returns, replacements etc.
- 5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
- Market Researchers and Analysts
- Marketing agencies we may engage from time to time
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
- 6. INTERNATIONAL TRANSFERS (for example to our preferred email marketing platform or CRM)
Whenever we transfer your personal data we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- If you are a resident of the European Union, we will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
- 7. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisationincluding engaging data processing services that have appropriate security measures in place. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
- 8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. In some circumstances, we may delete identifying components of your data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- 9. THIRD- PARTY LINKS
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- 10. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portabilityof data and (where the lawful ground of processing is consent) to withdraw consent.
If you wish to exercise any of the rights set out above, please email us at solevitality@optusnet.com.au.
In order to respond to any request, we will require the following information:
- your name and address; and
- your contact telephone numbers
There is no fee chargeable to access your personal data however we may charge a fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances. As a security measure to ensure your data is not disclosed to any person who has no right to receive it we may request further information from you.
We try to respond to all legitimate requests within 48 hours unless the request is complex or where there are multiple requests. If our response is likely to exceed 48 hours you will be notified.
If you are not happy with any aspect of how we collect and use your data please contact us first so we may attempt to resolve your issue immediately. You also have the right to complain to the Office of the Australian Privacy Commissioner (https://www.oaic.gov.au), the Australian supervisory authority for data protection issues.
(C)Sole Vitality June 2018