WHealth Naturopathy Privacy Policy
Last updated 15/05/24
Privacy Policy
This is the Privacy Policy of WHealth Naturopathy 39 574 521 984. If you have any questions please email Ashleigh McCloskey at hello@whealthnaturopathy.com.au
WHealth Naturopathy values and respects the privacy of the people we deal with. WHealth Naturopathy is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act) and other applicable privacy laws and regulations.
This Privacy Policy (Policy) describes how we collect, hold, use and disclose your personal information, and how we maintain the quality and security of your personal information.
What is personal information?
“Personal information” means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. In general terms, this includes information or an opinion that personally identifies you either directly (e.g. your name) or indirectly.
What personal information do we collect?
If you engage with us via this website, or choose to become our client or customer, we may ask to collect the following kinds of personal information from you, including:
· Contact information including name, mailing or street address; date of birth; email address; phone number
· Your preferences and opinions applicable to our offerings and services
· Information that allows us to tailor our content to your needs when you sign up for one of our events.
· Your IP address, and information about your browsing history to help us improve the usability and appeal of our website.If you are an employee or contractor, or propose working with me in that capacity, information about your qualifications, skill and work experience may be required.
· If you are a supplier or prospective supplier, information about your business skills, services, products & prices.
Where practicable we will only collect personal information about you directly from you. However, in some circumstances we may obtain personal information from a third party. If this information is obtained contrary to this Privacy Policy and the Privacy Act, we will destroy or de-identify such information within a reasonable period. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with our services or otherwise interact with you.
How do we collect your personal information?
We collect your personal information directly from you when:
· You interact with us over the phone;
· You interact with us in person;
· You interact with us online, including social media
· You participate in surveys or questionnaires;
· You attend an event hosted or presented by WHealth Naturopathy
· You subscribe to our mailing list;
· You opt in to receive a free resource from us
· You apply for a position with us as an employee, contractor or volunteer;
· You provide us with a testimonial
· our website automatically collects information about you and your activities on our site (including analytics and cookies)
· A third party supplies your information to us
Collecting personal information from third parties
Where practicable we will only collect personal information about you directly from you. However, in some circumstances we may obtain personal information from a third party. If this information is obtained contrary to this Privacy Policy and the Privacy Act, we will destroy or de-identify such information within a reasonable period.
How do we use your personal information?
We use personal information for many purposes in connection with our functions and activities, including the following purposes:
· To provide you with information or services that you request from us;
· To deliver to you a more personalised experience and service offering;
· To improve the quality of the services we offer;
· For internal administrative purposes;
· For marketing and research purposes;
· To share the latest news and developments relevant to our work
Professional Considerations
We are subject to the following regulations regarding the collection of personal information:
· As a naturopath, I owe you a professional duty of confidentiality. I take this responsibility very seriously and will always strive to promote your best interests;
· If you choose not to be completely honest with me, I may not be able to provide you with the services that you request; and
· Maintaining confidentiality except with explicit consent, when required by law or there is serious risk to the client or another person.
You may choose not to provide us with your personal information. However, if you do not provide us with accurate information, we may not be able to provide you with the best service possible.
Disclosure of personal information to third parties
We may disclose your personal information to third parties in accordance with this Policy in circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to:
· our third party service providers (for example, our IT providers);
· Australia Post or courier services;
· our marketing providers;
· our professional services advisors;
· ● [insert]].
Transfer of personal information overseas
Some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Australia. Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if:
· you have given us your consent to disclose personal information to that third party; or
· we reasonably believe that:
o the overseas recipient is subject to a law or binding scheme that is, overall, substantially similar to the APPs; and
o the law or binding scheme can be enforced; or
· the disclosure is required or authorised by an Australian law or court / tribunal order.
Sensitive information
We understand that some information is particularly sensitive, and that you are trusting us to keep this information confidential.
The sensitive information we collect from you may include:
· Your birth date
· Your personal medical history and family medical history
· Information on your lifestyle
We will only collect sensitive information by methods that are reasonably secure, such as:
· Through our intake form and case notes in [Booking system] when you book an appointment
· In a telehealth consultation via [Booking system] or face to face
When you send us information in an email please note that email may not be sufficiently secure. If the information is extremely sensitive, ask us about alternative ways to share it with us.
The reason why we collect your sensitive information is:
· So that we can provide you with the services you have requested from us.
· To ensure we are providing you with the most effective health services.
How do we protect your personal information?
WHealth Naturopathy will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:
· Ensuring sensitive information is stored on password protected computer and two factor authenticated software.
· Taking measures to restrict access to only personnel who need that personal information to effectively provide services to you;
· Having technological measures in place (for example, anti-virus software, fire walls);
· Having robust physical security of our office premises and files
Collection of Information from Minors
Sensitive information may be collected from children under the age of 18 in the following circumstances:
· In the presence of their parent or guardian, or
· With their guardian’s full knowledge and consent.
All information collected from minors is securely stored in accordance with this privacy policy.
Disclosure of information
We may disclose your information if required under the following circumstances:
· To provide you with the services you have requested
· To send you products that you have purchased
· Where disclosure is necessary to carry out your instructions, such as corresponding with someone else on your behalf, requesting pathology tests and ordering supplements
· Where we use support services to assist us in our business
· To engage in professional supervision, although any information we share under these circumstances is de-identified to preserve client confidentiality
· To refer you to other service providers at your request
Who disclosures are made to
You consent to us sharing relevant information, on a strictly need-to-know basis, with:
· People you authorise us to correspond with, as reasonably required to carry out your instructions
· Our employees
· Third party providers who assist with
o Accounting
o Administration
o Professional supervision
o Email marketing
o Legal or financial advice
o Website maintenance
o Technological services.
Legal disclosure
We will also disclose your information if required by law to do so or in circumstances permitted by the Privacy Act – for example, where we have reasonable grounds to suspect that someone is engaging in unlawful activity, or misconduct of a serious nature, that relates to our functions or activities, and in response to a subpoena, discovery request or a court order.
As mentioned above, your information may also be stored with a third-party provider, where it will be managed under their security policy. The following security policies may apply during our work together:
· Cliniko - https://www.cliniko.com/security/
· Mailchimp - https://mailchimp.com/about/security/
· Squarespace - https://www.squarespace.com/privacy
· Stripe - https://stripe.com/docs/security
· Xero - https://www.xero.com/au/security/
Online activity
Cookies
The WHealth Naturopathy website uses cookies. A cookie is a small file of letters and numbers the website puts on your device if you allow it. These cookies recognise when your device has visited our website before, so we can distinguish you from other users of the website. This improves your experience and the WHealth Naturopathy website.
We do not use cookies to identify you, just to improve your experience on our website(s). If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our website’s functionality may be affected.]
Website analytics
We use Google Analytics to collect information about your use of our website so that we can get strategic information about how our website is being used and improve its functionality. You can find out more about the information Google collects and how it is used here:
https://support.google.com/analytics/answer/6004245.
Google also provides an add-on for your browser that you can use to opt-out and prevent your data being used by Google Analytics. You can access that add-on here:
https://tools.google.com/dlpage/gaoptout.
I may also combine information provided by you with information gathered from Instagram and Facebook. Their privacy policy is found at https://privacycenter.instagram.com/policy/. Facebook’s policy is found at https://www.facebook.com/privacy/policy/
Squarespace also sets cookies to prevent cross-site request forgery (CSRF). You can find out more about the information squarespace collects here:
https://www.squarespace.com/cookie-policy
Direct marketing
We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
You may opt-out of receiving marketing communications from us at any time by [following the instructions to “unsubscribe'' set out in the relevant communication] / [contacting us using the details set out in the “How to contact us” section below].
Retention of personal information
We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example record-keeping obligations.
How to access and correct your personal information
WHealth Naturopathy will endeavour to keep your personal information accurate, complete and up to date.
If you wish to make a request to access and / or correct the personal information we hold about you, you should make a request by contacting us and we will usually respond within 30 days.
Links to third party sites
WHealth Naturopathy website may contain links to websites operated by third parties. If you access a third party website through our website, personal information may be collected by that third party website. We make no representations or warranties in relation to the privacy practices of any third party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website. Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.
Notification of Change
When we update our Privacy Policy, we will post a copy of the revised policy on our website.
Notification of Breach
If we have reason to suspect that a serious data breach has occurred and that this may result in harm or loss to you, we will immediately assess the situation and take appropriate remedial action. If we still believe that you are at risk, we will notify the Office of the Information Commissioner and either notify you directly, or if that is not possible, publicise a notification of the breach on this website.
Inquiries and complaints
For complaints about how WHealth Naturopathy handles, processes or manages your personal information, please contact Ashleigh McCloskey hello@whealthnaturopathy.com.au. Note we may require proof of your identity and full details of your request before we can process your complaint.
Please allow up to 30 days for WHealth Naturopathy to respond to your complaint. It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with WHealth Naturopathy’s response to a complaint, you have the right to contact the Office of Australian Information Commissioner (at www.oaic.gov.au/) to lodge a complaint.
How to contact us
If you have a question or concern in relation to our handling of your personal information or this Policy, you can contact us for assistance as follows:
[insert email address]
Contact number
[0417317268 or online phone]
Post
Attention: Ashleigh McCloskey
Address: [insert office address]