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Privacy Policy

Last updated: June 16, 2023

Get Brain Fit (“us”, “we”, or “our”) operates the Get Brain Fit website (the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.

We will not use or share your information with anyone except as described in this Privacy Policy.

Privacy Statement
Get Brain Fit! is committed to protecting the privacy of an individual’s personal information. The following sets out how we aim to protect the privacy of your personal information, your rights in relation to your personal information managed by us, and the way we collect, use and disclose your personal information.
In handling your personal information, we will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the thirteen Australian Privacy Principles in the Privacy Act.
We have policies and procedures in place to ensure that:
● personal information is managed in an open and transparent way
● the privacy of personal information of participants and staff are protected
● we collect and handle personal information fairly
● personal information we collect is used and disclosed for legally permitted purposes only
● we regulate access to and correction of personal information
● we maintain the confidentiality of personal information through appropriate storage and security.
The kinds of information we collect
Consumer personal information is collected to provide care and services. Personal information we collect could include your:
● name, address, telephone number and email address
● date of birth
● gender
● advocate or emergency contact’s telephone number and email
● health information
● diversity status (ethnicity, lifestyle preferences).
● where you use our mobile application, Retiink App, information you choose to input including when you use the calendar function, appointments you input;
● where you use our career assessment or our transferable skills assessment, answers to questions you choose to answer relating to your interests, skills, strengths and employment choices;
● your credit card or payment details (through PayPal, our third party payment processor);
● your preferences and/or opinions;

● 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 Services, including through the use of Internet cookies, your communications with our online Services, 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 Services, 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.
Sensitive information: The types of sensitive information we may collect about you include:
 details of your health appointments; and
 your health information which you choose to provide to us.
Unless otherwise permitted by law, we will not collect sensitive information about you without first obtaining your consent.
How we collect personal information
Participant personal information may be collected from:
● you, the participant
● your family members or significant others
● your advocate
● your doctor or other service providers or facilities.
● From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
We will collect personal information directly from you unless:
● we have your consent to collect the information from someone else
● we are required or authorised by law to collect the information from someone else
● it is unreasonable or impractical to do so.
You can withdraw your consent at any time by contacting us; although you should be advised that this may impact on our capacity to provide services.
Purpose of collecting personal information
Personal information is collected for the purposes of providing care and services. The information may be used to:
● provide support services
● enable service providers and medical practitioners to provide care and services

Disclosure of personal information
We may disclose your personal and health information, for the purpose of your care and services, to:
● service providers who assist us in providing care and services, medical practitioners, external health agencies such as the ambulance service, hospitals, the National Disability Insurance Scheme, and other relevant government organisations
● a person you have nominated as being your advocate, e.g. parent, child or sibling, spouse, a relative, a member of your household, a guardian, an enduring power of attorney, or a person you have nominated to be contacted in case of emergency, provided they are at least 18 years of age.
Personal information: We may collect, hold, use and disclose personal information for the following purposes:
● to enable you to access and use our Services and in order for us to provide our Services to you, including to provide you with our career assessment or transferable skills assessments;
● to contact and communicate with you about our Services;
● for internal record keeping, administrative, invoicing and billing purposes;
● for analytics, market research and business development, including to operate and improve our Services, associated applications;
● for advertising and marketing, including to send you promotional information about our products and services and information that we consider may be of interest to you;
● to comply with our legal obligations and resolve any disputes that we may have;
● if you have applied for employment with us; to consider your employment application; and
● if otherwise required or authorised by law.
Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:
● any purposes you consent to;
● the primary purpose for which it is collected;
● secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you;
● to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent; and
● if otherwise required or authorised by law.

Disclosure of personal information to third parties
We may disclose personal information to:
 third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
 our employees, contractors and/or related entities;
 our existing or potential agents or business partners;
 anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;

 courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
 courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
 third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and
 any other third parties as required or permitted by law, such as where we receive a subpoena.
Overseas disclosure: Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of Australia, including but not limited to, Malaysia or the Netherlands.
We will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles or we will take such steps as are reasonable in the circumstances to protect your personal information in accordance with the Australian Privacy Principles.
We may not use or disclose personal information for a purpose other than providing care and services, unless:
● you have consented
● the purpose is related to providing care and services, and you would reasonably expect disclosure of the information for that purpose
● we believe on reasonable grounds that the disclosure is necessary to prevent or lessen a serious and imminent threat to your life, health or safety or a serious threat to public health or public safety
● we have reason to suspect unlawful activity and disclosure is required or authorised by law.
We will not disclose your personal information to an overseas recipient.
Security of personal information
We take all reasonable steps to ensure that the personal information we hold is protected against misuse, loss, unauthorised access, modification or disclosure. We hold personal information in both hard copy and electronic forms in secure databases on secure premises and on secure, cloud-based technology, accessible only by our authorised staff.
Accessing the personal information that we hold about you
Under the Privacy Act, you have a right to access your personal information that is collected and held by us. If at any time you would like to access or change the personal information that we hold about you, or you would like more information on our approach to privacy, please contact us.
To obtain access to your personal information, you will have to provide us with proof of identity. We will take all reasonable steps to provide access to your personal information within seven (7) days from your request.

Your rights and controlling your personal information
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.
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.
Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email 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.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information.
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 promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. 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 in response to your complaint. You also have the right to contact the relevant privacy authority.
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, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, 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.
Cookies
We may use cookies on our online Services 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. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.
Links to other websites
Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact our Privacy Officer at:
Nicole Maree Elizabeth Yeates t/as Get Brain Fit ! ABN 78 897 876 287
Last update: 15/06/2023
Privacy data breaches
In the event that your personal information is lost, stolen or subject to unauthorised access or disclosure, we will implement our Management of Data Breach Policy and Procedure.
Privacy complaints
All complaints regarding privacy can be lodged via our complaint handling process.
At all times, privacy complaints will:
● be treated seriously
● be dealt with as promptly as possible
● be dealt with in a confidential manner
● not affect your existing obligations or affect the commercial arrangements between you and us.
You will be informed of the outcome of your complaint following completion of the investigation.

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