PRIVACY POLICY
1.Overview
This privacy policy (Privacy Policy) sets out how Jeffrey Morgan ABN: 35 625 444 242 (‘Us’, ‘We’ or ‘Our’) collects, stores, uses, protects and shares your personal information.
When you engage Us to provide you with any goods or services you have requested, communicate with us or use any of Our other services including Our website you agree to the collection, storage, usage and disclosure of your personal information by Us in the manner described in this Privacy Policy.
We reserve the right to amend this Privacy Policy at any time by posting the amended terms on Our website. If We make material changes to this Privacy Policy, we will notify you by means of a notice on Our website and/or other means so that you can access and review the changes.
2. Definitions
“Personal Information” means information that can be associated with a specific person and can be used to identify that person and includes your information. Information that has been made anonymous or aggregated so that it cannot be used, whether in combination with other information or otherwise, to identify a specific user is not personal information.
3. Collection
We collect personal information in several ways, including:
- when you provide information directly to Us in person, by phone or in writing (whether electronic, via Our communication tools or otherwise).
- when you visit and/or use Our website, in which case, we record information sent to us by your computer, mobile device or other access device; and
- from third parties such as Our related entities, service providers to Us, operators of linked websites, applications, and advertising on Our website.
What we collect
We collect the following types of personal information to provide you with access to and use of Our website and for the purposes provided for in this Privacy Policy:
- your name, phone number, mobile telephone number, email address, physical address, and other contact information.
- financial information such as credit card or bank account numbers.
- records and content of communications with Us or any other person including when using any website communication tools.
- personal information based on your activities on Our website.
- personal information you provide to us through any correspondence, or shared by you from other social media applications, services, or other websites.
- to the extent permitted by law, other personal information provided by or obtained from third parties.
- personal information from your interaction with Our website and its content, such as your website usage information and IP address.
4. How personal information is used
Our primary purpose in collecting, using, and storing your personal information is for Our general business operations, to:
- effectively provide you with our goods and services requested.
- communicate with you.
- respond to your enquiries or complaints.
- supply you with generalised, targeted, or personalised marketing, advertising and promotional notices, offers and communications based on your preferences, and measure and improve Our marketing and promotions to you.
- operate, generate content, and provide customer support and billing services (including updates and improvements).
- meet Our legal and regulatory obligations, and to detect, investigate and prevent potentially unlawful acts or omissions or acts or omissions with the potential to breach Our Terms of Sale, this Privacy Policy, or other policies.
- enforce Our Terms of Sale, this Privacy Policy, or other policies.
Marketing and Opting out
- We may use your personal information for:
- promoting and marketing of Our current and future goods and services; and
- informing you of upcoming events and special promotions and offers.
You may withdraw your consent to us collecting, storing, using, and disclosing your personal information for marketing purposes in accordance with this Privacy Policy. You may opt out of receiving Our marketing, advertising and promotional notices, offers and communications by communicating this to Us in writing at the email address below or by clicking unsubscribe links published in Our electronic marketing and promotional material.
Disclosure to third parties
Notwithstanding the above, you agree that We may disclose your personal information to:
- enforce Our terms of service, this Privacy Policy and Our other policies.
- comply with any applicable laws, request by a governmental agency or regulatory authority or legally binding court order.
- respond to or resolve claims that a member has violated the rights of others.
- protect a person’s rights, property, or safety.
- Our directors, staff, contractors, professional advisers, and related entities.
- outsourced service providers who assist Us to provide Our goods and services such as information technology providers, shipping/delivery providers, Our financial institutions or e-commerce payment providers (including banks and other financial institutions to collect and receive payment) and marketing advisers (including in relation to fee collection, fraud investigations and website operations);
- third parties to whom you expressly ask us to send, or consent to us sending, your personal information.
- such entities that We propose to merge with or be acquired by and in such case, we will require that the new entity following the merger or acquisition adhere to this Privacy Policy.
5. Use of website and Cookies
As with most websites, when you visit or use Our website, we may record anonymous information such as your IP address, time, date, URL, pages accessed, and documents downloaded.
We (or a third-party providing services to Us) may use cookies, pixel tags, "flash cookies”, or other local storage provided by your browser or associated applications (each a Cookie and together Cookies). A Cookie is a small file that stays on your computer or device until, depending on whether it is a sessional or persistent cookie, you turn your computer or device off or it expires (typically between 7 and 30 days depending on user settings).
Cookies may be used to provide you with Our range of services including to identify you on Our website, remember your preferences, customise and measure the effectiveness of Our website and Our promotions, advertising and marketing, analyse your usage of Our website, and for security purposes.
Cookies may collect and store your personal information. This Privacy Policy applies to personal information collected via Cookies. You may adjust your internet browser to disable Cookies. If Cookies are disabled, we may not be able to provide you with the full range of Our services.
You also may encounter Cookies used by third parties and placed on certain pages of Our website that We do not control and have not authorized (such as web pages created by another user). We are not responsible or liable for the use of such Cookies.
Our website may also include links to third party websites (including links created by users or members) and applications and advertising delivered to Our website by third parties (Linked Sites). Organizations that operate Linked Sites may collect personal information including using Cookies. We are not responsible or liable for Linked Sites and recommends that you read the privacy policies of such Linked Sites before disclosing your personal information.
6. Accessing and amending your personal information
We acknowledge that you have a general right to access the information We hold about you. However, we may not be required to provide you with access to your personal information to the extent that (amongst other things):
We reasonably believe that access would pose a serious impact to the life, health, or safety of any individual, or to public health or public safety; and
- giving access would have an unreasonable impact on the privacy of other individuals; or
- the information relates to existing or anticipated legal proceedings between the entity and the individual, and would not be accessible by the process of discovery in those proceedings; or
- giving access would be unlawful.
You can request access to your personal information by contacting Our Privacy Manager (details below). You may be required to pay an administrative charge for associated matters, such as copying charges, but not for making the request itself. We may require up to 30 days from notice to comply with your request to access your personal information.
If We refuse your request to access the information, we hold about you, we will provide you with Our reason/s for doing so.
If you have access to an online account with Us, you may login to your account and access your personal information.
7. Accuracy of personal information
We rely on you to provide us with accurate and up to date information about you. If there are any changes to your personal information during any interactions with the LIFESTYLE PROGRAM™, you are responsible for advising us.
We will take reasonable steps to ensure your personal information is kept up-to-date, accurate, complete, and not misleading. If you believe the personal information, we hold about you is incorrect or inaccurate, you can request that We update this information by contact Our Privacy Manager (details below).
We will correct information We hold about you if We discover, or you are able to show to a reasonable standard, that the information is incorrect or inaccurate. If you seek a correction and We disagree that the information is incorrect, we will provide you with Our reasons for taking that view.
8. Storage and security
We will take reasonable steps to protect the security of your personal information from misuse, interference, or loss by restricting access to the information from unauthorized access or disclosure.
We hold personal information electronically and in hard copy paper format. For information that is stored electronically, we take reasonable security measures to ensure that personal information is protected by firewalls, secure logon processes and encryption technologies. Hard copy information is securely stored in an appropriate and secure filing system.
9. What do we do if there is a data breach?
In the event of a data breach, such as the unauthorized loss, use or disclosure of personal information, we will assess and respond in line with Our applicable policies and procedures, which incorporate the requirements contained in the Privacy Act. Pursuant to our obligations under the Privacy Act, we will notify you where your personal information is involved in an eligible data breach that is likely to result in serious harm. Such notification will also include making recommendations about the steps you should take in response to the breach. Where required by law, the Australian Privacy and Information Commissioner will also be notified of eligible data breach.
10. Overseas Disclosure
Any personal information provided to Us may be transferred to, stored by, or disclosed to an overseas recipient. For example, we may use a server hosted overseas to store data, which may include your personal information or engage an organization located overseas to assist Us in Our general business operations.
Before your information is disclosed to an overseas recipient, we will take steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach privacy laws in relation to your personal information.
However, such reasonable steps may not apply, if We reasonably believe (when disclosing your personal information to the overseas recipient) that:
- the recipient of the information is subject to a law, that has the effect of protecting the information in a way that, overall, is at least substantially like the way in which the Australian Privacy Principles protect the information; and
- there are mechanisms that an individual can access to take action to enforce the protection of their privacy.
11. Unsolicited information
We will take reasonable steps to determine whether information We receive may be unsolicited information. If We believe that information is unsolicited information, we will destroy the information as soon as practicable or ensure that it is de-identified.
12. Anonymity
- Only where it is practicable to do so, we may allow you the option not to identify yourself when dealing with Us. However not identifying yourself to Us may make it difficult to effectively provide you with Our goods or services.
13. Sensitive Information
- We do not collect sensitive information unless it is specifically relevant and necessary for the purpose of Our general business operations and your express consent is first obtained.
14. Government Identifiers
- We will not use government identifiers such as your tax file number or Medicare number to identify you.
15. Complaints
- If you have reasons to believe that We have not managed your personal information in accordance with Our Privacy Policy, or complied with Our privacy obligations, please refer any concerns or complainants to Our Privacy Manager (details below).
- We will ensure your concerns or complaints are handled by Our Privacy Manager in an appropriate and reasonable manner.
16. Contact Us
If you have a question regarding this Privacy Policy or you would like to make a complaint, please contact the Privacy Manager at: