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Privacy

This is a privacy policy that sets out how we collect, use and disclose personal information, including sensitive personal information, in accordance with privacy laws. These laws are the (Australian Federal) Privacy Act 1988 (including the Australian Privacy Principles (APPs) and other Australian privacy and data protection laws, mandatory codes and other mandatory requirements.

We may modify or amend this privacy policy from time to time. We will display a notice on our website indicating when any such revisions have been made.

This Privacy Policy was last updated on 2nd November 2015.

Unless you notify us otherwise but only to the extent permitted by the Australian Privacy Principles, you consent to the collection of all information which is provided to us for use in accordance with this privacy policy.

We do not sell, rent or trade your personal information with any third party.

We will not otherwise disclose your personal information to any third party unless:

(a) that third party is a group company of ours, in which case that group company will only use and disclose your personal information in accordance with this privacy policy as if a reference in this privacy policy to us included a reference to that group company;

(b) that third party is a contractor engaged to provide products or services to us. This may include disclosure to contractors outside of Australia. Our agreements with such contractors require that they keep your personal information confidential and that they only use or disclose your personal information for the purposes of providing those goods or services to us;

(c) such disclosure is in connection with the sale of some or all of our business or assets; or

(d) you have consented for us to share the information for this purpose, or the disclosure is authorised by privacy laws, including to lessen or prevent a serious threat to life or health, to protect the personal safety of the public, if authorised or required by law, if we have reason to suspect that unlawful activity has been, is being or may be engaged in, to enforce the law or where necessary to investigate a suspected unlawful activity, or you would reasonably expect or we have told you that your personal information is usually used or disclosed to third parties in this way.

We will comply with APP 7 and the (Australian Federal) Spam Act 2003 in relation to any direct marketing by us, including:

(a) allowing an individual to opt out of receiving any further direct marketing from us; and

(b) in each written communication from us, setting out our business address, telephone number and, if the communication with that individual is made by fax, telex or other electronic means, a number or address at which we can be directly contacted electronically.

Where we use personal information for the purposes of business to business direct marketing, we rely on the exception in the Privacy Act to do so.

A cookie is a small file containing information specific to a user, passed through an internet protocol such as a web browser and stored on a device.

We use cookies and other technology to track access to, and use of, our website. The information gathered is not personally identifiable and is used to improve our website.

We may also be provided with cookies data, anonymous identifier data, device information, log information and other information, if provided by ad serving services or advertising networks and relating to use by other persons of third party websites serviced by those ad serving services or advertising networks. Many browsers and internet access devices are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser or configure your internet access device to either prompt you whether you wish to accept cookies on a particular site, or by default reject cookies. Please note that rejecting cookies may mean that some or all of the features and functionality of particular websites or Internet services will not be available to you.

An individual may request access to their personal information held by us. Subject to any permitted exception under privacy laws, we shall give that individual access to that information. If an individual notifies us that the information we hold about them is not accurate, we will take reasonable steps to correct that information. To the extent that we have received any personal information indirectly, we will notify that business that it has received a request from an individual to access or correct the personal information it has provided to us.

If you require access to your personal information, please email us at hello@kinela.com or call us on 1300 448 100. Before we provide you with access to your personal information we will require some proof of identity.

For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part.

If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the APPs (unless it would be unreasonable to do so).

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it. If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please Contact Us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.

We retain personal information after we have used the personal information for the purposes for which we collected or received it.

If we retain such personal information, it will only be used for the following purposes:

(a) as required by or under Australian law, or a court / tribunal order;

(b) as required for professional indemnity insurance; and

(c) in accordance with our back-up archive policy.

When no longer required, Kinela uses its best endeavours to ensure that all such information will be destroyed in a secure manner and in a reasonable time frame.

The security of your personal information is important to us.

We will take all reasonable steps to protect the security of all personal information entrusted to us, following the guidance of the Australian Privacy Commissioner as to what we need to do to meet our legal obligations under APP 11 (security of personal information).

In particular, we take reasonable steps to prevent the personal information we hold about you from misuse, interference or loss, and from unauthorised access, modification or disclosure. This includes the use of technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of your personal information.

Sometimes our website contains links to other websites. When you access a website other than our website, we are not responsible for the privacy practices of that site. We recommend that you review the privacy policies of each website you visit.

If you:

(a) would like to access or inquire about any personal information we hold about you;

(b) have a query in relation to this Privacy Policy; or

(c) would like to make a complaint about our handling of personal information,

please contact us using the details below.

A: Level 3, 37 Darlinghurst Rd Potts Point, NSW 2011

E: hello@kinela.com

T: 1300 448 100

If you wish to make a complaint about an alleged breach of privacy laws, we ask that you send us your complaint in writing to the email address listed above. We endeavour to respond to complaints within a reasonable period (usually 30 days). If you are not satisfied with our response, you may make a complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992 or by email at enquiries@oaic.gov.au.

We are Well Movement Pty Limited 92 601 713 517 trading as Kinela.