The Wellbeing Studio

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This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through this website (Site) and software available on this Site or via or our application (Software). In this Privacy Policy we, us or our means The Wellbeing Studio. When we collect, store and use your personal information, we do so in accordance with the rules set down in the European Union General Data Protection Regulation (EU) 2016/279 (the GDPR).

Personal information

Personal information: The types of personal information or personal data we may collect about you include:

your name;
your contact details, including email address, mailing address, street address and/or telephone number;
your age and/or date of birth;
your demographic information, such as postcode;
your preferences and/or opinions;
information you provide to us through customer surveys;
details of products and services we have provided to you and/or that you have enquired about, and our response to you;
your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
additional personal information that you provide to us, directly or indirectly, through your use of our Site, Software, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
any other personal information requested by us and/or provided by you or a third party. We may collect these types of personal information directly from you or from third parties.

Collection and use of personal information

We may collect, hold, use and disclose personal information for the following purposes:

to enable you to access and use our Site, Software, associated applications and associated social media platforms;
to contact and communicate with you;
for internal record keeping and administrative purposes;
for analytics, market research and business development, including to operate and improve our Site, Software, associated applications and associated social media platforms;
to run competitions and/or offer additional benefits to you;
for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
to comply with our legal obligations and resolve any disputes that we may have; and
to consider your employment application.

Disclosure of personal information to third parties

We do not share your data with any external agencies

Our responsibilities as a ‘controller’ under the GDPR

Controllers are defined by the GDPR as natural or legal persons, a public authority, agency or other body to which personal information or personal data has been disclosed, whether via a third party or not, and who determines the purposes and means of processing personal information. We are a collector under the GDPR as we collect, use and store your personal information to enable us to provide you with our goods and/or services. As a collector, we have certain obligations under the GDPR when collecting, storing and using the personal information of EU citizens. If you are an EU citizen, your personal data will:

be processed lawfully, fairly and in a transparent manner by us;
only be collected for the specific purposes we have identified in the ‘collection and use of personal information’ clause above and personal information will not be further processed in a manner that is incompatible with the purposes we have identified;
be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal information is processed;
be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information);
be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal data was collected;
be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.

We also apply these principles to the way we collect, store and use the personal information of our clients. Specifically, we have the following measures in place, in accordance with the GDPR:

Data protection policies: We have internal policies in place which set out where and how we collect personal information, how it is stored and where it goes after we get it, in order to protect your personal information.
Right to ask us to erase your personal information: You may us to erase personal information we hold about you.
Right to ask us to restrict data processing: You may ask us to limit the processing of your personal information where you believe that the personal information we hold about you is wrong (to give us enough time to verify if the information needs to be changed), or where processing data is unlawful and you request us to restrict the processing of personal information rather than it being erased.
Maintain Records of Processing Activities:
Notification of data breaches: We will comply with the GDPR in respect of any data breach.

Our responsibilities as a ‘processor’ under the GDPR

Where we are a processor, we have contracts containing certain prescribed terms in our contracts with controllers. Depending on circumstances, we can be a controller or processor or controller and processor. In addition to:

our contractual obligations with controllers (where we are solely a processor); and
our legal obligations under the GDPR as a controller (where we are both a controller and processor) as a processor we also have the following direct responsibilities:

not to use a sub-processor without the prior written authorisation of the data controller;
to co-operate with supervisory authorities;
to ensure the security of its processing;
to keep records of processing activities;
to notify any personal data breaches to the data controller; and
to employ a data protection officer and appoint (in writing) a representative within the European Union if required by the GDPR. (These are not required for the company at the present time). To the extent the GDPR applies to our processing of your personal data, you agree that the GDPR Data Processing Schedule set out on our Site governs such processing.

Your rights and controlling your personal information

Choice and consent: Please read this Privacy Policy carefully. By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. If you are under 16 years of age, you must have and have, and warrant to the extent permitted by law to us that you have, your parent or legal guardian’s permission to access and use the Site and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it. Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us. Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict how we process your personal information, we will let you know how the restriction affects your use of our Site or products and services. Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party (data portability). Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date. Complaints: If you believe that we have breached the Australian Privacy Principles or an article of the GDPR and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact the Office of the Australian Information Commissioner if you wish to make a complaint. Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as the pseudonymisation and encryption of personal information, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Cookies and web beacons

We may use cookies on our Site from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.

For any questions or notices, please contact our Privacy Officer at: The Wellbeing Studio via email to info@thewellbeingstudio.net

Last update: 01 January 2022

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