Vitruvian Investments Pty Ltd ACN 630 548 846 (“we”, “our” and “us”) is committed to responsible privacy practices and to complying with the Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act”) to the extent they apply to us.
WHAT IS PERSONAL INFORMATION?
- “personal information” has the meaning set out in the Privacy Act. Essentially, personal information is information or an opinion about an individual who is reasonably identifiable.
- “Process” means any operation or set of operations performed on data or sets of data, whether or not by automated means, including use, collection, storage, disclosure, sharing, and/or transmission (as applicable).
What types of personal information do we collect?
The types of personal information we collect from you depends on the circumstances in which the information is collected.
- We may collect identifying information including your name, address, email address, phone numbers, your date of birth/age, your height and your weight.
- We may collect answers you provide to questions we ask and other information in relation to your dealings with us.
- We may collect sensitive information which is health information related to your use of our products and/or services, for example, if you have any existing injuries.
We may also collect information about you from time to time, for example, how many times per week you exercise, the date and time you exercise, the total time you spend exercising, the exercises you select (including resistance and repetitions), the velocity of your exercises, how many times you intend to exercise, why you are exercising using our products and/or services, and about your diet.
- If you apply for employment with us, we may also collect information for the purpose of considering your application including your qualifications and resume as well as reference information from your nominated referees.
- If you are an individual contractor to us, we may also collect information relevant to your engagement with us including qualifications, work history, resume, reference information from your nominated referees, bank details, feedback from supervisors and training records.
In addition to the types of personal information identified above, we may collect personal information as otherwise permitted or required by law.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect personal information in a number of ways. The most common ways we collect your personal information are:
- directly from you when you provide it to us or our agents or contractors;
- via our app, website or when you deal with us online (including through our social media pages);
- from publicly available sources;
- from our related companies;
- and from third parties (for example, from referees if you apply for a position as an employee or contractor with us).
FOR WHAT PURPOSES DO WE PROCESS (INCLUDING COLLECT, USE, AND DISCLOSE) YOUR PERSONAL INFORMATION?
The purposes for which we Process your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.
We may Process your personal information: for the purposes for which we collected it (and related purposes which would be reasonably expected by you); for other purposes to which you have consented; and as otherwise authorized or required by law.
In general, we Process your personal information so that we can do business together and for purposes connected with our business operations.
Some of the specific purposes for which we Process personal information are:
- to respond to you if you have requested information (including via our websites or social media channels or via an email or other correspondence you send to us);
- to provide goods or services to you or to receive goods or services from you;
- to advertise or administer rewards, surveys, competitions, products, services or other promotional activities or events conducted, sponsored, provided or managed by us or our business partners;
- to enable you to use our apps and other applications that you download;
- to enable you to participate in any loyalty or incentive programs that we operate;
- to improve our goods and services;
- to verify your identity, address, and age or eligibility to participate in a marketing activity;
- to consider you for a job with us (whether as an employee or contractor) or in the context of other relationships with us;
- to address any issues or complaints that we or you have regarding our relationship;
- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner; and
- for research purposes (whether by us or our employees, contractors, related bodies corporate and authorised third parties). In particular, we may use your sensitive information in a de-identified format for academic research.
WHAT HAPPENS IF YOU DON’T PROVIDE PERSONAL INFORMATION?
Generally, you have no obligation to provide us any personal information requested by us. However, if you choose to withhold requested personal information, we may not be able to provide you with our products and/or services, or allow you to participate in the marketing activities that depend on the collection of that information.
TO WHOM DO WE DISCLOSE PERSONAL INFORMATION?
This may include disclosing your personal information to the following types of third parties:
- our employees and related bodies corporate;
- our contractors and other third parties that provide goods and services to us (including website and data hosting providers, and other suppliers);
- our accountants, insurers, lawyers, auditors, and other professional advisers and agents;
- payment system operators;
- if you are an individual contractor to us or a prospective employee, to our related companies and HR-related service providers (e.g. for outsourced payroll processing);
- any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
- in the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors;
- third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
- otherwise as permitted or required by law.
Where we disclose your personal information to third parties we will use reasonable efforts to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the Australian Privacy Principles under the Privacy Act.
If you post information to public parts of our websites or to our social media channels, you acknowledge that such information (including your personal information) may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.
DOES PERSONAL INFORMATION LEAVE AUSTRALIA?
We may disclose personal information outside of Australia to our related bodies corporate, service providers, and other third parties, including those located in the United States of America.
Except in some cases where we may rely on an exception under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the Australian Privacy Principles in the Privacy Act in relation to such information.
HOW DO WE PROTECT PERSONAL INFORMATION?
Please notify us immediately if you become aware of any breach of security.
ACCURACY OF THE PERSONAL INFORMATION WE HOLD
We try to maintain your personal information as accurately as reasonably possible. We rely on the accuracy of personal information as provided to us both directly (from you) and indirectly.
LINKS, COOKIES, AND USE OF OUR WEBSITES AND APPLICATIONS
We may use “cookies” and similar technology on our websites and in other technology applications. The use of such technologies is industry-standard and helps to monitor the effectiveness of advertising and how visitors use our websites/applications. We may use such technologies to generate statistics, measure your activity, improve the usefulness of our websites/applications, and to enhance the “customer” experience.
HOW CAN YOU ACCESS, CORRECT AND REQUEST DELETION OF PERSONAL INFORMATION WE HOLD ABOUT YOU?
- become aware that any personal information we hold about you is incorrect;
- wish to update your information; and/or
- wish to request deletion of any personal information that hold about you,
You have the right to request deletion of your personal information. There may be legal or other reasons why we need to keep it and if so we will tell you about these reasons, unless it would be unreasonable to do so.
If you send us personal information that we have not requested, or we consider that the personal information you provide to us is not required for our business, we may de-identify or delete this information without notifying you to protect your privacy.
QUERIES, COMMENTS, AND COMPLAINTS ABOUT OUR HANDLING OF PERSONAL INFORMATION
When contacting us please provide as much detail as possible in relation to your question, comment or complaint.
We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner.
How can you contact us?
Please address all privacy complaints and/or requests to:
15 Gordon Street, West Perth, Western Australia 6005, Australia
If you wish to unsubscribe from our direct marketing, you can also contact us using the contact details listed above.