Natural Wellness Technologies Pty. Ltd.
1. We respect your privacy
1.1. Natural Wellness Technologies Pty. Ltd. respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information.
1.2. "Personal information" is information we hold which is identifiable as being about you.
2. Collection of personal information
2.1. Natural Wellness Technologies Pty. Ltd. will, from time to time, receive and store personal information you enter onto our website, provided to us directly or given to us in other forms.
2.2. You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
2.3. Additionally, we may also collect any other information you provide while interacting with us.
3. How we collect your personal information
4. Use of your personal information
4.1. Natural Wellness Technologies Pty. Ltd. may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.
4.2. Natural Wellness Technologies Pty. Ltd. may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.
5. Disclosure of your personal information
5.1. We may disclose your personal 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. Personal information is only supplied to a third party when it is required for the delivery of our services.
5.2. We may from time to time need to disclose personal information 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.
5.3. We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Natural Wellness Technologies Pty. Ltd., www.vively.com.au, its customers or third parties.
5.4. Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.
5.5. 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 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.
6. Security of your personal information
6.1. Natural Wellness Technologies Pty. Ltd. is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
7. Access to your personal information
7.1. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at email@example.com.
7.2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.
8. Complaints about privacy
8.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to 10/255 Pitt Street, Sydney, New South Wales, 2000. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
10.1. When you visit our website
When you come to our website (www.vively.com.au) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
10.3. Third party sites
Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Natural Wellness Technologies Pty. Ltd. is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
Vively Health Pty Ltd
Last updated 20 July, 2022
Vively's privacy principles
Your health data belongs to you (not us), and you can decide how it is used
: We believe you should control your own biological health data, and our goal is to make it easy for you to see, export, and delete your own information. It's also up to you to decide how your data on Vively can be used. If you don't wish to contribute your personal data for product improvement and metabolic health research purposes, you can opt out of that sharing by sending us an email at firstname.lastname@example.org.
We'll never access or use your information in ways you haven't agreed to.We respect your right to privacy and will protect your information
: We'll work to collect as little information as needed to provide a valuable service, and we will continually look for ways to collect less. We will keep your information secure by prioritising data security in every decision we make, and by ensuring that our security practices stay up-to-date.We don’t monetise your data
: We don’t sell (or sell access to) your data to third parties (for advertising, or for other purposes). You may be asked to contribute your data to research initiatives that will help to improve public health policy and the health care system at large. By contributing your data to research, you help researchers form a detailed understanding of how people are living, how poor health outcomes develop, and how optimal outcomes can be built.
1. What personal information do we collect?
- name and contact details;
- age, date of birth and gender;
- details about your current health;
- your health data, imported from your device;
- your glucose data, via a CGM;
- your logs and usage of the app, including meals, activities, habits and notes;
- your interactions with Vively support;
- shipping information; and
- billing and payment details
Your health information is classed as ‘sensitive information’, which generally receives a higher level of protection under the APPs than other types of personal information.
Your health data imported from your device will only occur if you explicitly enable this feature in the app, Vively will import your Activity, Sleep, and Heart Rate data from Apple Health or Google Fit. You can disable these integrations from your account settings in-app.
When using Vively, you'll likely add meal photos, titles, notes, and activities. You can also import sleep data, heart rate data, and activity data from your device. Access to this information is limited to those with a business need, like support team members, data scientists, product managers, or engineers.
When you contact our Support team, we retain the chat or email log as part of our records. If you participate in product feedback sessions, we may record the sessions for future reference. We'll always let you know verbally if a call is being recorded.
2. How do we collect your personal information?
We collect personal information in several ways. We do so from you directly where possible (or from a legal guardian or representative if applicable).
We may ask you to complete forms or questionnaires, and provide additional information from time to time (sometimes, verbally; other times, in writing). We may also collect personal information about you from third parties if you have agreed that they can provide us with this information. For example, we may collect information from:
- your health insurance provider, if any;
- Government funding sources, if any (such as Medicare); and
- third party health practitioners (such as your General Practitioner).
3. How do we use and disclose your personal information?
Where we hold personal information that was collected for a particular (primary) purpose we will generally use or disclose it only for that purpose and not for any other (secondary) purpose unless you have consented, or we are otherwise permitted or required to do so (whether under the APPs, the Act, or another law).
Use of personal information
The purposes for which we may use your personal information could include:
- to assess whether we can safely provide you with our services;
- to personalise in-app insights, education, and resources to improve your experience;
- If you request help from our support or engineering teams, we may need to access your account and associated information for troubleshooting;
- to research in the field of non-diabetic, wellness-focused glucose management. You may be asked to contribute your data to our ongoing product improvement and research studies;
- to maintain and administer your client file;
- to invoice you for our fees;
- to make payment claims to your health insurer (if any) and/or to any Government funding sources (such as Medicare);
- to contact you for follow up services and check-up reminders;
- to collect unpaid invoices; and
- to send information to you about our services.
Disclosure of personal information
The purposes for which we may disclose your personal information could include:
- making payment claims, and complying with audit and other legal obligations to the funder(s) (whether a health insurer, Government or both);
- seeking services or a second opinion from, or making a referral to, third party healthcare providers;
- debt collection, through a debt collection provider, if you do not pay our invoices;
- to respond in an emergency situation; and
- to comply with a written request from you.
We will also disclose your personal information if properly directed to do so by an appropriate government, regulatory or statutory body (including a court or tribunal).
4. How do we make sure that your personal information is accurate?
We take reasonable steps to ensure that the personal information we hold about you is accurate, up-to-date and complete. These steps include amending our records when you let us know that any of your information has changed, and reminding you to let us know whenthere is a change.
5. How do we protect and store your personal information?
We take steps to protect the personal information we hold (whether in hard or electronic format) against loss, misuse, unauthorised access, use, modification and/or disclosure. We ensure that hard copies of records are kept in locked files. We have security processes in place regarding computer access, and we take steps to ensure that electronic data is backed up.
When we no longer require your personal information we may securely destroy or de-identify your records in accordance with Australian laws.
6. Accessing your personal information
You have the right to access the personal information that we hold about you. You can contact us in writing, by email or by telephone and request access to your personal information. Our contact details are set out in Section 9 of this Policy. We will always try to meet your request within a reasonable time.
In some circumstances, your request for access may be denied. These circumstances include:
- if we no longer hold any personal information about you;
- if your request is frivolous or vexatious;
- if the information requested relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
- if providing access would be unlawful; and
- if denying access is required or allowed by law.
If we deny you access to the information you have requested, we will give you written reasons when we respond to your request.
We may charge you a reasonable fee for access to some types of information, limited to an amount to recoup our costs. Charges may include document retrieval, photocopying, X-ray and model costs, and delivery costs.
7. Correcting your personal information
To enable us to provide you with the best service, it is important that the information we hold about you is accurate, up-to-date and complete. You will need to provide us with any changes to your personal information (including change of address, name, telephone numberand other health providers) to enable us to update your records.
8. Overseas (cross border) disclosure
Some of our service providers from time to time may be located overseas and/or they may store information outside of Australia. For example data storage providers or web hosts may use servers, systems and cloud computing facilities outside of Australia;
If we become aware of such matters, we will:
- take reasonable steps to ensure that the overseas recipient does not breach the APPs; or
- seek to establish a reasonable belief that the overseas recipient is subject to protections which, overall, are at least substantially similar to those in the APPs (and which can be enforced).
We will also disclose personal information overseas if you give us informed consent in accordance with the APPs.
9. Further information and resolving your concerns
If we are unable to resolve a complaint with you directly, you may consider making an external complaint.
We collect personal information that is necessary to provide services to you.
The types of personal information that we collect from clients and prospective clients include: