PRIVACY POLICY

Last updated: June 11, 2020

PHATT PRIVACY POLICY

At Putting Health at the Top Pty Ltd (ACN 614 091 039) (Phatt), your privacy is important to us and we are committed to ensuring the confidentiality and security of your personal information.

All references to ‘us’, ‘our’, ‘we’, means Phatt.

This Privacy Policy outlines how we collect, use, disclose and protect your personal information, as required by the Privacy Act 1988 (Cth) (Privacy Act). It also sets out how you can access and change your information, how you can ask a question or make a complaint.

Definition of Personal information

It is information or an opinion that identifies an individual or allows their identity to be readily worked out from the information. It includes information such as your name, address, telephone number and email address.

Health information

Health information is classified as ‘sensitive information’ for the purposes of the Privacy Act. Health information, which may be necessary to facilitate appropriate participation in our weight loss program that focuses on a lifestyle adjustment towards healthier living. (Phatt Program), will only be collected with the consent of the participant or as otherwise permitted by law.

Collection of personal information

We only collect personal information that is reasonably necessary for Phatt’s business functions and activities. The personal information we may collect and handle include your name, email address, telephone number, country of residence and your Facebook name.

We may request certain health information about your medical history, test results, family medical history, current lifestyle, activities, that may be relevant to the Phatt Program. We will only collect health information if you voluntarily submit such information to us.

We collect personal information in a number of ways including:

  1. from you directly by personal contact when you sign up to become a member of our Facebook page or sign up for the Phatt Program, as well as through mail, telephone, email and online communications and interactions with us, including your responses to surveys relating to Phatt’s service improvement.
  2. from you directly by personal contact when you sign up to become a member of our Facebook page or sign up for the Phatt Program, as well as through mail, telephone, email and online communications and interactions with us, including your responses to surveys relating to Phatt’s service improvement.
  3. your account activity;
  4. third parties including public resources, affiliate retailers and referrers.

Management of personal information

We may hold your personal information in physical and electronic form both at our premises and with the assistance of our service providers that may be located in the USA. We implement a range of measures to protect the security of that information. We are also required to take reasonable steps to destroy or de-identify information when no longer needed for any permitted purpose.

We train our staff to handle personal information and restrict access where appropriate.

Use and disclosure of personal information

Our main use of your information is to administer your services with us in order to:

  1. verify your identity and personal information;
  2. prevent, detect and prosecute fraud and other unlawful activity;
  3. manage our relationship with you;
  4. conduct research and statistical analysis with the aim of improving our services;
  5. undertake periodic testing to ensure the accuracy of existing services;
  6. for marketing and promotion purposes.
  7. facilitate any process relating to any acquisition or potential acquisition of an interest in all or part of our business.

Without your personal information, we may be unable to do these things.

We may contact you on an ongoing basis by social media, telephone, email and text message to provide you with information about third party products and services which might be suitable for you, unless you ask us not to do so or legal restrictions apply. We try to limit our customer contact program to acceptable levels, but if you wish to exercise your right to opt out (remembering that opting out could stop us contacting you about any of our services that may benefit you), please contact us as set out below.

We are not responsible for the privacy of any information you may choose to share or reveal in any public forum (e.g. the Phatt Facebook pages etc.) or for the privacy practices of websites that are operated or owned by third parties.

The Phatt Program is not designed for or directed to children and is intended only for use by individuals who are 18 years and older. 

Direct marketing

From time to time, we may use the personal information collected from you for direct marketing purposes, promotions, special offers and other information which we think you may find interesting.

We may contact you by telephone, electronic messages (eg. email), online (including social media, websites and mobile apps) and other means for these purposes.

If we do contact you in this way, it will only be in relation to matters that customers would reasonably expect us to contact them directly about. And we will ensure that our marketing activities comply with applicable law.

If you no longer wish to receive any direct marketing communication from us, please follow the instructions for unsubscribing in our direct marketing communications. If there are no instructions, please contact us as set out in the section below.

We do not sell personal information to other third party organisations to allow them to contact you for direct marketing purposes.

Disclosure of your Personal Information

Phatt will disclose your personal information in the following circumstances:

(a)            if required by law;

(b)            if Phatt believes, in its absolute discretion, it is in the public interest;

(c)             to seek feedback, or monitor or improve quality of service;

(d)            to entities who assist Phatt in providing, administering, supporting, improving, promoting and marketing the Phatt Program; to suppliers, contractors, debt collectors, data storage and management companies (including providers of cloud services), website hosting service providers, and interactive advertisers;

(e)            to companies that promote and market, or conduct research to help Phatt improve and target the Phatt Program; or

(f)              where Phatt otherwise obtains your permission to disclose the information, for example, where you opt to allow unrelated third parties access to certain documents.

Phatt may share aggregated, non-personally identifiable information publicly, for example, to show trends about the general use of Phatt’s Program.

 

Our website

Our website at puttinghealthatthetop.com (the Website) may use cookies. A cookie is a small file which checks for permission to be placed on your computer’s hard drive. If permitted (e.g. through your browser’s settings), the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

You can visit and browse the Website without disclosing any personal information. Our system may record information such as the date and time of your visit, your computer’s IP address, the pages accessed, and any information downloaded. This information is used for statistical, reporting and website administration and maintenance purposes. No Personal Information is collected if you are simply browsing the Website.

We may combine the personal information we collect from you with information that we receive from and about you in other contexts and from other sources, including third parties.

Security

You agree that no transmission of data over the Internet is guaranteed as wholly secure and that any information you provide to Phatt through the Internet, including via email, is at your own risk. You agree that, even though Phatt uses its best endeavours to secure your personal information, such as email encryption, Phatt cannot guarantee that any information sent or accessed electronically is secure.

You may also assist Phatt in keeping your personal information secure by maintaining the confidentiality of your account information and notifying Phatt immediately if there is any unauthorised use of your account, or any other breach of security relating to your account.

Links

The Website contains links to third party websites. Phatt is not responsible for the information on these sites, or their privacy policies. Phatt may keep track of your interaction with third party websites provided on the Website in order to improve Phatt’s services and to aggregate statistics for the benefit of Phatt and other third party service providers.

Accessing and correcting your personal information

Under privacy laws you may have the right of access and correct your personal information that we hold. Please provide as much detail as you can about the particular information you seek, in order to help us locate it. We may need to verify your identity. If anything is inaccurate or incorrect, please let us know. We will provide our reasons if we deny any request for access to or correction of personal information. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

 

Complaints

If you have any questions or concerns or about our Privacy Policy or about the privacy of your Personal Information, or if you are concerned that your privacy has been compromised, please contact Phatt at the following email address phattweightloss@gmail.com. If we do not resolve a complaint to your satisfaction, you also have the right to complain to the Office of the Australian Privacy Commissioner, Tel: 1300 363 992 or email: privacy@privacy.gov.au

Amendments

Phatt may amend this Privacy Policy from time to time. If Phatt does make amendments, the amended Privacy Policy will be published on the Phatt Website.

You agree that it is your responsibility to check for updates to Phatt’s Privacy Policy. You further agree that your continued use of the Website is acceptance of Phatt’s amendments to the Privacy Policy.

Further information

If you have any questions, concerns or feedback about privacy, please contact:

Phatt Administration

Email:  phattweightloss@gmail.com