1. INTRODUCTION
The Bodycare Workplace Solutions Group respects and upholds your rights under the Australian and New Zealand Privacy Principles contained in the Privacy Act 1988 (Cth) and the Privacy Act 1993 (Privacy Act). This Privacy Policy lets you know what personal information of yours we hold, what we do with it, who we will disclose it to and how you can access the personal information we hold about you. You can also find out here how to change inaccurate personal information and how to opt out of receiving communications from us.
While this Privacy Policy has been developed to comply with the Privacy Act we have also taken steps to ensure that, if you tell us you are located in the European Union, we will seek to give you the protections available to you under the General Data Protection Regulation (“GDPR”). Together, we refer to these two pieces of legislation as “Privacy Law”. We set out later in this policy those additional rights.
2. DEFINITIONS
The following terms have the following meanings:
Cookies means a small text file that is stored on a user’s computer/phone for record-keeping purposes.
Information means either Personal Information or Non-personal Information.
Non-personal Information means any information that does not reveal your specific identity or does not directly relate to an individual.
Personal Information has the same meaning as under the Privacy Act and may include information such as:
(a) name;
(b) postal address or street address;
(c) email address;
(d) telephone number and other contact details;
(e) age or date of birth;
(f) credit card information;
(g) your device ID, device type, geo-location information; and
(h) other information you provide to us in using our services.
Primary Purposes include, but are not limited to, those purposes listed in Section 6(a)-(e) of this Privacy Policy.
Secondary Purposes include the use of Information for any purpose that is not defined as a Primary Purpose.
Sensitive Information means Personal Information that may be sensitive to the person in which the Information is about.
3. WHY DOES THE BODYCARE WORKPLACE SOLUTIONS GROUP COLLECT YOUR PERSONAL INFORMATION?
The Bodycare Workplace Solutions Group only collects Personal Information for the purposes of conducting the Services. The Personal Information The Bodycare Workplace Solutions Group collects from you will include Information you give us when you:
(a) register or subscribe to the Website;
(b) communicate with us through correspondence, chats, emails or when you share information with us from other social applications, Services or Websites;
(c) interact with our sites, Services, app content and advertising;
(d) complete a transaction with us; or
(e) contact us.
The Bodycare Workplace Solutions Group may collect, hold, use and disclose your Personal Information for the following purposes: –
(a) to enable you to access and use our Services or Website;
(b) to operate, protect, improve and optimise our Service, Website, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
(c) to send you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you;
(d) to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
(e) to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
(f) to comply with our legal obligations, resolve any disputes we may have with any of our users, and enforce our agreements with third parties; and
(g) to consider your employment application.
The Bodycare Workplace Solutions Group only collects Personal Information in circumstances where you consent to the collection of this Information, or it is reasonably necessary for, or directly related to, the purposes outlined above.
4. HOW DOES THE BODYCARE WORKPLACE SOLUTIONS GROUP COLLECT AND HOLD YOUR PERSONAL INFORMATION?
Where possible, The Bodycare Workplace Solutions Group will generally collect your personal information directly from you. We may also collect personal information from publicly available sources, our Website, direct sales and service enquiries or events with which you request further information.
If, The Bodycare Workplace Solutions Group holds Personal Information that was collected for a Primary Purpose, then The Bodycare Workplace Solutions Group must not disclose the Personal Information for a Secondary Purpose, unless users have consented to the use of the Personal Information or the users would reasonably expect that The Bodycare Workplace Solutions Group would use the Information for the Secondary Purpose which is directly related to the Primary Purpose.
At times, your Personal Information may be processed via a third-party plugin or integrated third party gateway provider(s).
If we collect Information about an individual or company from a third party, we will take reasonable steps to ensure that the individual is made aware of the matters above. In the event that The Bodycare Workplace Solutions Group receives unsolicited Personal Information, then we will, as soon as practicable but only if lawful, destroy the Information or ensure the Information is kept confidential.
4A. USE OF AI-ASSISTED NOTE-TAKING TOOLS?
To support the delivery of our Services, The Bodycare Workplace Solutions Group may use secure, AI-assisted note-taking technologies to document consultations, assessments, and other service interactions. These tools may transcribe, summarise, or analyse conversations in real-time or retrospectively to assist our clinicians and consultants in maintaining accurate records and improving service quality.
The use of an AI enhanced note taker has been adopted to enable clinicians to focus more on communication and client care during sessions, rather than being distracted by manual note-taking. AI tools are used only to assist human clinicians in record-keeping and do not make clinical or administrative decisions
Before using AI-assisted note-taking tools, we will inform clients and, where required, obtain their consent. Clients may request that AI note-taking not be used during their session.
What is Saved: The AI note taker helps by transcribing the session and then providing a summary of that session. The transcript of the session will be deleted and will not make up part of a patient file, while the summary is saved. Audio of the session is never saved.
Any Personal Information captured through these tools will be handled in accordance with this Privacy Policy and applicable Privacy Law. We will only use AI-assisted note-taking tools that meet our standards for data security, confidentiality, and clinical governance. Where required, we will take reasonable steps to ensure that any third-party providers of these tools comply with relevant privacy obligations.
If you have concerns about the use of AI-assisted note-taking in your interactions with us, please contact our Privacy Officer.
5. WHAT PERSONAL INFORMATION ABOUT YOU DOES THE BODYCARE WORKPLACE SOLUTIONS GROUP COLLECT AND HOLD?
The Bodycare Workplace Solutions Group collects two distinct types of Personal Information:
- information relating to our commercial clients/suppliers and the contact people in those organisations; and
- information about individuals who consent to providing Personal Information to us (including Sensitive Information) as part of The Bodycare Workplace Solutions Group providing Services to its commercial clients (such as from employees or prospective employees of those clients)
We may also collect Personal Information, including Sensitive Information, from you if required by the Services we are performing for our clients. This can include health information which will be only collected with your consent.
For commercial clients, credit information may also be collected for establishing a client account with us (but this will usually be corporate and commercial, rather than Personal Information).
6. WHAT DOES THE BODYCARE WORKPLACE SOLUTIONS GROUP DO WITH YOUR PERSONAL INFORMATION?
We may use your Personal Information for Primary Purposes, including:
(a) to provide functionality of our Services and related support, including to provide our contracted Services or receive products or Services from you;
(b) to provide you with marketing and promotional materials and opportunities;
(c) to provide administrative information to you, for example, information regarding our Services and changes to our terms, conditions and policies;
(d) to further our reporting and trending, to improve our products and Services;
(e) to accomplish our business purposes, including:
(i) ensuring our internal processes function as intended and are compliant with legal, regulatory and contractual requirements;
(ii) ensuring that fraud and security monitoring purposes are effective in detecting and preventing cyberattacks or attempts to commit identity theft;
(iii) responding to legal duties, such as requests from public and government authorities.
If you no longer wish to use our services, you can cease to provide us with your information.
Your information will normally be stored in our internal database and our domestic IT system.
7. WHO WILL THE BODYCARE WORKPLACE SOLUTIONS GROUP DISCLOSE YOUR PERSONAL INFORMATION TO?
Services
The Bodycare Workplace Solutions Group may disclose your Personal Information:
(a) to our employees and related bodies corporate;
(b) to our affiliates for Primary Purposes and Secondary Purposes.
(c) to third-party service providers or suppliers who provide Services such as Website hosting, data analysis, payment processing Services, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar Services;
(d) to professional advisers, dealers and agents;
(e) to third parties to permit them (or their own customers) to send you marketing communications;
(f) to you, through message boards, chat, profile pages, blogs and other Services to which you are able to post information and materials;
(g) Where you use our app to meet the public health monitoring requirements of a client of ours, we may provide details collected about your health to that client.
(h) to business partners in the context of a corporate transaction. If The Bodycare Workplace Solutions Group is involved in a sale or business transaction, The Bodycare Workplace Solutions Group will retain a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer of other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring or target entity and its advisors; and
(i) to your employer if the Service provided is a Challenge insofar as you have consented to participate in this Challenge. This means your name, email address and other details you have volunteered during the registration process may be shared with your employer. Data entered during the course of the Challenge will only be shared with your employer as part of a deidentified aggregate report or if you have been selected to win a prize; and
(j) as required by law.
With your consent, sensitive information may be provided to health Services providers, your employer and/or prospective employer or where otherwise required by law.
