Effective Date: 17/10/2014
Protecting your privacy: 12WBT Trading Pty Ltd ABN 31 154 009 622 or Level 5, 14 Foster Street Surry Hills NSW 2010 (“us, we, our” or “12WBT”) are committed to protecting the information about you that we collect, store and use when you provide it to us at our web and mobile sites: www.12wbt.com and mobile application: 12WBT Daily (Website). We manage your information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth). This document describes how we manage any personal information we have collected about you from the Website.
2. COLLECTION & USE OF PERSONAL INFORMATION
2.1 What personal information about me does 12WBT hold, and how it is collected
When you register to become a member of the Website, or when you register your interest to sign up in the future, you will be asked to complete an online form to submit different information about you to us. Such information includes:
- your name;
- your contact details such as your telephone number, physical address and email address;
- your date of birth;
- information that allows us to process your payment to us, such as bank account details and credit card information;
- a brief biography about yourself such as your hobbies, interests, occupation and relationship status; and
- links to any websites, social media sites or blogs that you maintain.
If you do not provide us with the necessary information, you may not be able to complete the registration and receive the information from us.
Purchases made on our online store
If you make purchases on our online store, then you will be asked to complete an online form as part of the purchase. We may collect information such as:
- your name;
- your contact details such as your telephone number and email address;
- information that allows us to process your payment to us, such as bank account details and credit card information; and
- your delivery address.
Competitions and promotions
From time to time we may organise and run various competition and promotions for users of the Website. As part of these competitions and promotions, we may ask you to submit other personal information about yourself, such as your height, weight, marital status, age, fitness levels and nutrition details.
You do not have to provide us with your health information, however this means that you may not be eligible to enter some competitions, nor able to receive tailored information specific to your needs.
User submitted content
The Website allows you to post and submit content, including photographs and images, height, weight, marital status, age, fitness levels and nutrition details. You do not need to post or submit any content, however, if you do, we collect the information that you submit.
We also collect any other information you provide to us (whether orally, by mail or email or online).
We may ask to track location-based information from your mobile device while downloading or using our Mobile Apps or Services in order to tailor your experience. If you don’t grant permission then we do not collect any location-based data.
2.2 What does 12WBT do with my personal information?
We collect, hold and use your personal information for a number of purposes, as outlined below: Providing services to you and operating the Website
In general, we use the information that we collect to:
- assist us in providing goods and services to you;
- contact you or respond to your queries;
- display, update and maintain the content of the Website;
- tailor your experience of the Website and our communications to you; and
- send information about future events, regular email communications or newsletters (both electronic and hardcopy) outlining news, services or events.
Running Competitions and Promotions
If we collect information from you as part of any competitions or promotions, we use the information that we collect in profiling your fitness, displaying the results of competitions, promoting the service and encouraging other members of the Website.
We may also use the information that we collect from you:
- to advertise our services and the Website. However, we will seek your consent before we use your photograph publicly for this purpose;
- for our internal administrative, marketing and planning requirements;
- to compile and report statistics, with all the relevant personal and/or proprietary information de-identified prior to the completion of such statistics; and
- for purposes that are expressly permitted under any agreement with you.
2.3 To whom will 12WBT disclose my personal information?
We do not disclose contact information about you publicly or to other third parties by us unless it is authorised or required by law (or when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on us in relation to the Website) or as otherwise outlined in this policy.
We may display personal information about you (including your health information and your profile photograph) on the Website. This is for the purposes of publicly profiling your fitness, displaying the results of competitions, promoting our services and Website and encouraging other members. If you do not wish this to happen, then you must contact us where directed below.
We will display your user submitted content as part of the Website. The Website may include functionalities that allow you to control whether or not the public or other users of the Website are able to view your user submitted content. We will use reasonable endeavours to implement your selection.
From time to time, we will also disclose your personal information (on a confidential basis) to agents and others that we use in the ordinary operation of our business, such as account and billing, shipping and fulfilment, marketing and promotion, user experience research and surveys, website hosting and support and maintenance. We will only disclose your information to the extent required for the limited purpose of the third party providing services contracted to us so that we may service you.
If 12WBT is involved in a merger, acquisition, or sale of all or a portion of its assets, your PII or other information may be part of the transferred assets.
We may also disclose aggregated data (in a form that does not identify you individually) to our advisors for the purposes of conducting market and user experience analysis.
While we store the majority of the personal information that we collect from your in Australia, we may from time to time store some of the information in a computer server located in the United States. We will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles.
We publish customer testimonials on our website, in social media profiles, on our Youtube channel and within advertising creative material. These testimonials may contain personally identifiable information. We obtain your written consent at the time the testimonial is recorded. If you want your testimonial removed please contact us at email@example.com.
2.5 Manner of collection
We will use reasonable endeavours to only collect information directly from you. If you are disclosing details of another person (for example, a minor on whose behalf you are registering), it is your sole responsibility to ensure that that person understands and consents to the collection, use and disclosure of their personal information in the manner set out in this policy.
3. INFORMATION COLLECTED BY OUR WEBSITE
3.1 Tracking of user experience
We use Google Analytics Advertising products: Remarketing with Google Analytics and Google Analytics Demographics and Interest Reporting. Google Analytics collects data about our site traffic via Google Advertising cookies and anonymous identifiers. Data collected via these Google products is not linked with any personally identifiable information you submit while on our Website. If you wish to opt out of the Google Analytics data collection, you may do so on Google’s website at https://tools.google.com/dlpage/gaoptout/.
As is true of most web sites and mobile applications, we and, in some instances, our third party tracking-utility partners gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the Website, to track users’ movements around the Website and to gather demographic information about our user base as a whole.
Technologies such as: cookies, beacons, tags and scripts are used by 12WBT and our partners (marketing and development partners), affiliates, or analytics or service providers (online customer support provider, email marketing system). These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use local storage objects (LSOs) such as HTML5 to store content information and preferences [or – other uses].
Third Parties, with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity, use LSOs such as HTML5 to collect and store information.
3.3 Social Media Features
Our Website offers blogs or community forums that may be publicly accessible (or accessible by other users of the Website). You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
3.5 Single Sign-On
You can log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.
4. MARKETING MATERIAL
We may use your personal information to provide you with material, promotions and communications from time to time about services and products available to you from us, or from other service providers in partnership with us, or to invite you to continue to use our services. This information will only come from us. We will not on-sell your personal information to other providers without your consent.
You may opt out of receiving promotional materials from us at any time by contacting us at email@example.com, or by following the ‘unsubscribe’ link on the relevant promotional emails.
5. PROTECTING AND MAINTAINING PERSONAL INFORMATION
We will take all reasonable steps to protect the information we hold about you from unauthorised access, use and disclosure, however we cannot guarantee that our systems and stored data will be completely free from third party interception or are free from corruption.
Certain parts of the Website (such as those parts that require you to provide us with your credit card number) provides the ability for you to transmit information to our Website in an encrypted form by using secure socket layer technology (SSL). However, other parts of the Website are not protected by any form of encryption to protect information you send from your computer to us over the Internet. Further, no method of transmission over the Internet, or method of electronic storage, is 100% secure. In light of this, we cannot ensure or warrant, and do not warrant, the security or privacy of your personal information, including payment and account details. You transmit this information at your own risk. If you have any questions regarding security you can contact us at firstname.lastname@example.org.
You are solely responsible for maintaining the security of your passwords and/or any account information. We will destroy or de-identify your personal information when it is no longer needed or required to be kept by law or to provide services to you. Please note that, as you may continue to have access to your account after your service subscription expires, we will continue to retain your personal information on the Website so that you may access it. You can manually delete your personal information on the Website by accessing your account. We will also preserve the content of any email or information you submit if we believe we have a legal requirement to do so, or if any form of email abuse is suspected.
If you use our Website to link to another site we encourage you to view their terms and conditions of use, privacy policies and security statements before disclosing any of your personal information on those sites.
6. ACCESSING PERSONAL INFORMATION
It is your responsibility to advise us of any changes to your personal details to ensure we can keep our records accurate and up to date. If you wish to access the information we hold about you, please submit a request email@example.com by logging into your account and making the appropriate changes. If you believe that the personal information we hold about you is incorrect, you are entitled to request amendment of such information. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it. You may also request that we delete the personal information that we hold about you. Please note that if we delete your contact information, we may not be able to provide you with the subscribed service.
If you request us not to use personal information in a particular manner or at all, we will adopt reasonable measures to observe your request but we may, to the extent permitted by law, still use or disclose your information if you subsequently consent to the disclosure or we believe the use or disclosure is reasonably necessary to assist a law enforcement agency or as otherwise required or authorised by law. If you know the information we hold about you is not accurate or complete, please notify us. We will respond to requests for access within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
7. PRIVACY CONCERNS
If you have any concerns about how we handle your personal information or require further information, please contact the Privacy Officer at firstname.lastname@example.org. Also use this contact if you no longer consent to receiving marketing material from us, or to the posting of your personal information on the Website.
This document represents our policy as at 17 October, 2014. We may change this document from time to time to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a prominent notice on this Website prior to the change becoming effective. Although we intend to observe this policy at all times, it is not legally binding on us in any way. From time to time we may regard it as necessary or desirable to act outside the policy. We may do so, subject only to any statutory rights you have under the Privacy Act or other applicable legislation. We encourage you to regularly review this statement to inform yourself of any amendments.
8. Contact Us
12WBT Trading Pty Ltd.
Level 5, 14 Foster Street Surry Hills NSW 2010 (ABN: 31 154 009 622)
Phone number: (02) 9046 3900
Copyright © [19 January 2010] 12WBT Trading Pty Ltd ABN 31 154 009 622. All rights reserved.