South Pacific Health Clubs knows that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly. We are committed to providing quality services to you and this policy outlines our ongoing obligations in respect of how we manage and protect your Personal Information.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include:
- Full name and contact details
- Age and date of birth
- Emergency contact details
- Debit/credit card details, bank account details
- Payment history
- Health or medical information – if you intend to use one of our facilities or services in a manner for which your health status may be a consideration
- Membership number
- Your usage of the club
- The products that you purchase from us
- Preferred communication methods
- Business name (in the case of a corporate membership) and business address
- Where applicable, your vehicle registration
- Where applicable, your student identification details
- Your image, if you are photographed at one of or clubs
- Health fund details
- Sensitive information (for more information see below)
Personal Information is obtained by lawful and fair means including directly from you and / or authorised third parties.
We may collect your personal information in a number of ways, including but not limited to:
- when you send South Pacific Health Clubs an e-mail, “contact us” message or any other form of written enquiry;
- via mobile sites, applications
- via South Pacific Health Clubs official social media pages that it controls, such as the official pages on Facebook and Instagram
- when you visit or telephone one of South Pacific Health Clubs venues to ask about our services
- when you sign up to use South Pacific Health Clubs, whether online or in person
- when you make a booking at one of South Pacific Health Clubs venues
- when you enter a promotion, competition, provide feedback or participate in a survey, market research or other promotional activities which South Pacific Health Clubs (or one of its agents) conducts
- when you sign up to receive South Pacific Health Clubs newsletters or marketing material
- if your photograph or video footage is taken at one of South Pacific Health Clubs venues via our surveillance cameras
- We collect your Personal Information for the primary purpose of providing our services to you. We may also use your Personal Information for secondary purposes closely related to the primary purpose in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information we will, when requested, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. You are not obligated to provide the requested information, however failure to do so may result in South Pacific Health Clubs being unable to provide services to you.
Personal information may be requested for a variety of reasons, including but not limited to;
- to facilitate the administration of your membership of the club, to manage our relationship with you, to communicate with you and assist you with queries and to facilitate bookings of classes and appointments with our own or third party service providers and other transactions.
- to provide and improve our services and operate our facilities (including as described above), or otherwise as required or authorised by law.
- advertise products and services, to carry out market data analysis so that we can continue to deliver enhanced services and facilities, to process payments and maintain accounts and records, to prevent crime and aid in the prosecution of offenders, to comply with the law and to administer and maintain membership records. In addition, we use this information to improve our platform, prevent or detect fraud or abuses of our website and enable third parties to carry out technical, logistical or other functions on our behalf. As part of conducting our business, personal information may also be used to maintain and develop our business systems, including testing and upgrading.
- send you newsletters and promotions and to conduct online surveys or surveys by telephone; prize draws; competitions and other promotions via email, social media, telephone or post. We will also use the information in the course of collecting your membership fees and any other payments that may be due to us from you.
- we use health information provided by you so that we can assess your general health, wellbeing and your readiness for physical exercise. If we need to collect sensitive information (such as health information), we will not collect that information unless we have first obtained your consent.
- we may also invite you to set up a profile with our preferred personalised wellness tracking system provider.
- we use social media platforms to undertake marketing activities to offer you products and services that we legitimately feel may be of interest to you, to generate leads and to drive traffic to our website.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
- For the primary purpose for which it was obtained
- For a secondary purpose that is directly related to the primary purpose
- With your consent; or where required or authorised by law
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Information from third parties may include but are not limited to;
- someone duly authorised to act on your behalf;
- your personal trainer;
- South Pacific Health Clubs commercial partners with whom South Pacific Health Clubs organises discounts or other promotional arrangements for members and customers;
- parents or guardians of underage members;
- a current member who undertakes to have obtained your prior consent (via refer a friend initiatives);
- debit and payment service providers who process transactions on behalf of South Pacific Health Clubs businesses;
- the Australian Tax Office (ATO) and the Australian Securities and Investment Commission (ASIC);
- public sources (directories, client lists, professional and trade associations, bankruptcy or court registry searches);
- your employer with whom South Pacific Health Clubs may have negotiated a corporate partnership;
- market researchers and direct marketing providers;
- South Pacific Health Clubs official pages on social media platforms and from people with whom you are friends with or otherwise connected to on social media platforms;
- Third party apps that are affiliated with South Pacific Health Clubs
Disclosure of Personal Information
Personal information about our members is an important tool for our business, and is used in many ways to help improve the products and services South Pacific Health Clubs offers.
Your Personal Information may be disclosed in a number of circumstances including the following:
- Third parties where you consent to the use or disclosure;
- Contractors, agents and suppliers South Pacific Health Clubs engages to provide products and/or perform services;
- Commercial partners with whom South Pacific Health Clubs has agreed information sharing arrangements with;
- Professional advisors such as legal professionals and accountants;
- Where required or authorised by law
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.
Access to your Personal Information
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
We will be able to provide you with most personal information we hold about you, although in some circumstances it may not be possible for us to provide you with access to all of your personal information.
South Pacific Health Clubs may refuse such a request if granting access to information could result in any of the following:
- poses a serious threat to life, health or safety;
- would have unreasonable impact on privacy of others;
- is frivolous or vexatious;
- relates to legal proceedings;
- reveals South Pacific Health clubs intentions or prejudice any negotiations;
- would be unlawful;
- is required or authorised by law or court/tribunal order;
- is likely to prejudice enforcement related activities; or
- relates to a commercially sensitive decision process.
In the instance we are not able to provide you with the requested information, we will notify you and give you the reasons why (except to the extent it would be unreasonable for us to do so).
South Pacific Health Clubs will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information, we may require identification from you before releasing the requested information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.