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1. ABC Coaching’s commitment to privacy:
1.1. ABC Coaching (“us”, “we” or “our”) is committed to safeguarding the privacy of our clients, staff and visitors of ABC Coaching, as well as those who visit our website.
1.2. ABC Coaching is bound by the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (applicable for Australian Based Businesses this will need to be changed if based in another country), and other laws governing how health service providers handle your Personal Information and Sensitive Information (including information about your health).
1.3. This Privacy Policy (Policy) sets out how we collect and treat your Personal Information and Sensitive Information. The Policy applies to our website www.abccoaching.example.com, which is operated by us, and to the products and services provided by us.
2. Definitions
In this Policy:
2.1. “Personal Information” is categorised as information held by ABC Coaching, that may identify you, or by which your identity might be reasonably determined. The information you provide us may include, amongst other things, your name, address, email address and phone number. It does not include “Sensitive Information”.
2.2. “Sensitive Information” means any information about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliation, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preference or practices, criminal record or health information.
[If your business collects sensitive information as defined under the Privacy Act (including but not limited to information regarding the health of clients) we recommend you engage a solicitor to review and consider the specific information you collect and provide advice. Collecting, holding and using sensitive information comes with. The significantly increased obligations and risk.]
3. Collection of Your Data
3.1. To provide our services to you, ABC Coaching may receive and store Personal Information and Sensitive Information (together, ‘your Data’) that you enter onto our website, provide to us directly or give to us in other forms, including our Waiver & Release Form and Participant Information Sheet.
3.2. Your Data may include your:
3.2.1. Contact details including name, phone number, address and email address;
3.2.2. Payment and billing information, which we may use to bill you for our services and to process your payments (including credit card details);
3.2.3. Health information (both physical and mental health) including information relating to injuries past or present, or whether you are pregnant;
3.2.4. Personal history and family history; and
3.2.5. Other information voluntarily provided by you.
Your Data is collected to ensure your safety and wellbeing, and that of other participants and facilitators at ABC Coaching, to send information, provide updates and process purchases of services and products provided by ABC Coaching.
3.3. Sensitive Information, which includes the definition of your Data relating to your health, will not be collected unless you consent to the collection of that information.
3.4. ABC Coaching collects your Data from you in a variety of ways, including [it is important to consider all of the ways that your business collects data, including but not limited to in-person, via a website or online platform, social media and when your service is provided.]
3.5. We may collect additional personal Data at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your contact or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with us in any other way.
3.6. We may receive your Data from third parties. Those third parties may include your medical practitioners, hospitals, clinics, lawyers and/or family members. If we do, we will protect and use this information as set out in this Policy.
4. Use of Your Data
4.1. Personal Information collected by us will only be used and disclosed for the purpose for which it was collected as set out below. This includes maintaining your account and contact details, providing you with our products and services, and processing payments.
4.2. ABC Coaching may use Personal Information collected from you to provide you with information and updates on our services, additional products, or opportunities available to you.
4.3. We may use your Personal Information to improve our products and services and better understand your needs. [Consider how your business may contact those bound by the privacy policy]
4.4. We may from time to time use your Personal Information for another purpose where it would be reasonably expected by you or if permitted by the Privacy Act. This includes to effect or enforce a transaction, or procure advice from legal and accounting firms, auditors and other consultants.
4.5. Sensitive information will only be used and disclosed for [X].
5. Disclosure
5.1. ABC Coaching may disclose your Personal Information (but not Sensitive Information) to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
5.2. Personal Information is only supplied to a third party when it is required for the delivery of our services.
5.3. We may from time to time need to disclose Your Data to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
5.4. We may use Your Data to protect the copyright, trademarks, legal rights, property or safety of ABC Coaching, www.abccoaching.example.com, its clients or third parties.
5.5. We may also use and share aggregate or non-personally identifying information about clients for market analysis, research, marketing or other purposes.
5.6. We will not disclose, sell, share or trade your Personal Information to any third parties unless we first receive your consent, except as set out in this Policy.
5.7. We may provide health information (Sensitive Information) to [where health information is collected, we recommend that you seek independent advice to consider how this information is appropriately stored and shared (if required by law) with other parties].
5.8. Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia (applicable for Australian Based Businesses this will need to be changed if based in another country).
5.9. If 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 Information, Sensitive Information and non-personal information 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.
5.10. By providing us with your Data, you consent to the terms of this privacy policy and the types of disclosure covered by this policy. Where we disclose your Personal Information to third parties, we will request that the third party follow this policy regarding handling your personal information.
6. Security of Your Data
6.1. ABC Coaching is committed to ensuring that your Data is secure.
6.2. ABC Coaching will take reasonable steps to protect your Data from misuse, loss, unauthorised access and modification or disclosure. [Consider what physical, technical and administrative measures that your business uses (and are in place at the time of the privacy policy) to hold and protect that Data] and seek independent IT and legal advice where necessary to ensure that these processes are correctly set up.]
6.3. Despite taking appropriate measures to protect your Data used and collected by us, please be aware that no data security measures can guarantee 100% security all of the time. The transmission and exchange of information is carried out at your own risk.
6.4. We cannot guarantee the security of your Data that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of your Data, we cannot assure you that your Data we collect will not be disclosed in a manner that is inconsistent with this privacy policy.
6.5. You are solely responsible for maintaining the secrecy of any passwords and other account information pertaining to our Platform, apps or services.
7. Access to your Information
7.1. You may request details of your Data that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth) (applicable for Australian Based Businesses this will need to be changed if based in another country).
7.2. A small administrative fee may be payable for the provision of your Data. If you would like a copy of your Data which we hold about you or believe that any of your Data we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected]
7.3. We reserve the right to refuse to provide you with your Data that we hold about you, in certain circumstances set out in the Privacy Act.
8. Website
8.1. When you visit the website of ABC Coaching www.abccoaching.example.com, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc.
8.2. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
[Consider how your website will manage other issues such as Cookies and risks associated with access to Third-Party Websites. If this is applicable to your business, then we recommend seeking independent legal advice about this clause].
8. Website
8.1. When you visit the website of ABC Coaching www.abccoaching.example.com, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc.
8.2. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
[Consider how your website will manage other issues such as Cookies and risks associated with access to Third-Party Websites. If this is applicable to your business, then we recommend seeking independent legal advice about this clause].
8. Website
8.1. When you visit the website of ABC Coaching www.abccoaching.example.com, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc.
8.2. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
[Consider how your website will manage other issues such as Cookies and risks associated with access to Third-Party Websites. If this is applicable to your business, then we recommend seeking independent legal advice about this clause].
8. Website
8.1. When you visit the website of ABC Coaching www.abccoaching.example.com, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc.
8.2. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
[Consider how your website will manage other issues such as Cookies and risks associated with access to Third-Party Websites. If this is applicable to your business, then we recommend seeking independent legal advice about this clause].
12. Changes to privacy policy
12.1. Our Privacy Policy is subject to change.
12.2. ABC Coaching may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website, or through distribution by email. Please check back from time to time to review our privacy policy.
