Privacy Policy – Updated 7th August 2018
Niyama Naturopathic is owned and operated by Rachel Hulme. Our website address is: https://www.niyamanaturopathic.com.au.
Personal information
Personal information: The types of personal information or personal data we may collect about you include:
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Your name;
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Images of you;
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Your contact details, including email address, mailing address, street address and/or telephone number;
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Your age and/or date of birth;
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Your credit card details;
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Your demographic information, such as postcode;
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Your preferences and/or opinions;
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The information you provide to us through customer surveys;
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Details of products and services we have provided to you and/or that you have enquired about, and our response to you;
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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;
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Information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
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Additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
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Any other personal information requested by us and/or provided by you or a third party.
We may collect these types of personal information directly from you or from third parties.
Collection and use of personal information
We may collect, hold, use and disclose personal information for the following purposes:
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To enable you to access and use our Site, associated applications and associated social media platforms;
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To contact and communicate with you;
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For internal record keeping and administrative purposes;
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For analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
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To run competitions and/or offer additional benefits to you;
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For advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
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To comply with our legal obligations and resolve any disputes that we may have; and
Disclosure of personal information to third parties
We may disclose personal information to –
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Our employees, contractors and/or related entities;
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Our existing or potential agents or business partners;
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Payment systems operators;
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Sponsors or promoters of any competition we run;
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Credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
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Courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
Where we disclose your personal information to third parties, including data processors, we will request that the third party handle your personal information in accordance with this Privacy Policy. The third party will only process your personal information in accordance with written instructions from us and we require that the third party either complies with the privacy shield principles set out in the GDPR or another mechanism set out by applicable EU & Swiss data protection laws for the transfer and processing of personal information. When we refer to ‘processing’ in this clause and this Privacy Policy in general, we mean any operation or set of operations which is performed on personal information, whether or not by automated means, such as collecting, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available personal information.
By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia and, if you are a European Union (EU) citizen, to third parties that reside outside the EU. Where the disclosure of your personal information is solely subject to Australian privacy laws (and not subject to the GDPR), you acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.
Blog Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Storage and Security of Personal Information
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 such as the pseudonymisation and encryption of personal information, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information are carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
Cookies and web beacons
We may use cookies on our Site 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. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.
We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
Analytics
We use Google Analytics and Sumo to collect usage data for our website. These companies are third party services who may potentially have access to data provided by you on our website.
Links to other websites
Our Site 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.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
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.
Niyama Naturopathic 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.
What data breach procedures we have in place
Our data breach policy is in accordance to Australian Privacy Principles (APP). This includes reporting any breach of data to both the client and the APP.
Payment Data
If you make a purchase from Niyama Naturopathic, certain data is collected regarding the purchase in order to process the payment. The data subject may be required to provide certain payment and billing data directly to our third-party payment processing partners, including name, credit card number, security code, expiration date, billing address, and post code. Payments are collected through PayPal and Stripe.
Industry regulatory disclosure requirements
Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information.
The type of sensitive information we may collect about you includes: Health Information
We will not collect sensitive information about you without first obtaining your consent. Health information is collected via Simple Clinic.
Provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected, including:
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Providing services for a purpose that is directly related to the primary purpose for which the sensitive information was collected; and
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Data analytics purposes.
Sensitive information may also be used or disclosed if required or authorised by law.
Our responsibilities as a ‘controller’ under the GDPR
Controllers are defined by the GDPR as natural or legal persons, a public authority, agency or another body to which personal information or personal data has been disclosed, whether via a third party or not, and who determines the purposes and means of processing personal information. We are a collector under the GDPR as we collect, use and store your personal information to enable us to provide you with our goods and/or services.
As a collector, we have certain obligations under the GDPR when collecting, storing and using the personal information of EU citizens. If you are an EU citizen, your personal data will:
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Be processed lawfully, fairly and in a transparent manner by us;
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Only be collected for the specific purposes we have identified in the ‘collection and use of personal information’ clause above and personal information will not be further processed in a manner that is incompatible with the purposes we have identified;
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Be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal information is processed;
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Be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information);
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Be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal data was collected;
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Be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.
We also apply these principles to the way we collect, store and use the personal information of our Australian customers or clients.
Specifically, we have the following measures in place, in accordance with the GDPR:
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Data protection policies: We have internal policies in place which set out where and how we collect personal information, how it is stored and where it goes after we get it, in order to protect your personal information.
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Right to ask us to erase your personal information: You may us to erase personal information we hold about you.
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Right to ask us to restrict data processing: You may ask us to limit the processing of your personal information where you believe that the personal information we hold about you is wrong (to give us enough time to verify if the information needs to be changed), or where processing data is unlawful and you request us to restrict the processing of personal information rather than it being erased.
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Maintain Records of Processing Activities:
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Notification of data breaches: We will comply with the GDPR in respect of any data breach.
Our contact information –
Rachel Hulme
+61 478 536 566
2/106 Pittwater Rd Manly, NSW 2095 Australia
rachel@niyama.com.au