Privacy Policy

Welcome to the Wellbeing Hub, powered by Springday.

At Springday, your privacy and the security of your personal information is a major priority for us. We want our visitors to feel protected when visiting and using the Wellbeing Hub and our Programs, Tools and Online Community (collectively “the Platform”), which are available at url: myspringday.com.au and at any other website which we operate on behalf of our corporate partners (“Website”) (collectively the “Springday Services”).

This Privacy Policy describes what information we gather from you, how we use that information, and what we do to protect it. We hope that this Privacy Policy is straightforward and clear; however, if you have any questions about it, please e-mail: privacy@myspringday.com.au.

Within this Privacy Policy, the terms “Springday”, “ we”, “us” and “our” means Springday Pty Ltd ACN: 126 617 025.

Acceptance

By providing us with your personal and/or sensitive information or by visiting and using our Website,

Platform and/or any of the Springday Services, you confirm your acceptance of the terms of this

Privacy Policy and consent to the handling of your information in the manner set out in this Privacy Policy and in accordance with any other explanation you may be given at the time of providing your information. If you do not agree with the terms of this Privacy Policy, please do not provide us with your information.

1. What information does Springday collect?

Springday collects the following types of information:

Personally Identifiable Information

Personally Identifiable Information (“PII”) is information (or opinion) about an identified individual or an individual who is reasonably identifiable. PII may include, for example, your name, email address, birth date, phone number, gender and location.

PII may also include personal information which is treated as “sensitive information” under the Privacy Act 1988 (Cth). Sensitive information includes, for example, information or opinion about your health, your racial or ethnic origin, or your membership of a professional association, trade association or trade union.

Non-Personally Identifiable Information

Non-Personally Identifiable Information (“NPII”) by itself cannot be used to identify or contact you. NPII may include user IP addresses, browser types, domain names, and anonymous statistical data involving the use of our Website and Platform.

From time to time, NPII may be connected to other information we collect from you.

You do not have to provide PII to, for example, visit the Website; however, you do need to provide us with PII to subscribe to particular Tools, Programs and the Online Community, which are available on the Platform.

The type of information we collect from you will depend upon the type of interaction you have with us. Broadly speaking, the types of PII that we collect may include:

• from users of the Platform – for example:

o your name, email address, birth date, phone number, gender and location when you create your Profile;

o details of, for example, your lifestyle, health, fitness and recreational activities and associated goals;

o details of any steps you have taken via the Platform, for example, participation in a health or fitness challenge, booking a flu vaccination etc.

We may also collect data from, for example, any of the following which you may use:

o wearables and connected fitness devices and platforms, such as fitbit and Garmin;

o consumer health applications; and

o health data aggregators, such as Apple Health,

if you chose to connect them with Programs or Tools etc, which are available on the Platform or Website.

• from our corporate clients and suppliers – for example, full names of key contacts, employer name, work contact details (including address, phone number, fax number and email address).

• from job applicants and employees – for example, full name, contact details (including address, phone number and email address), driver’s licence details, job title, passport details, employment history and education details, names and contact details of referees, next of kin details (in the event of an emergency) and superannuation fund and Tax File Number details, if required by law, for example, under the Superannuation Guarantee (Administration) Act, the Superannuation Industry (Supervision) Act, theIncome Tax Assessment Acts and Taxation Administration Act.

2. How does Springday collect PII?

We may collect PII from you in a variety of ways, including at different places and times on our Platform or Website, such as when you become a subscriber.

We may collect your PII when you do any of the following, for example:

• join the Wellbeing Hub via the Platform and create and manage your profile;

• use the Wellbeing Check Tool, which is available on the Platform;

• choose customised content, Programs, Tools and incentives, including when you connect wearables and connected fitness devices and platforms (such as fitbit and Garmin), consumer health applications and/or health data aggregators (such as Apple Health) with particular Programs and Tools on the Platform;

• subscribe to receive our newsletter or promotional materials or sign up to a mailing list;

• participate in challenges on the Platform or enter competitions, surveys or other promotional activities available on the Platform or Website; and

• interact with us by phone, email, mail, or via the Website, a Platform or any of our social media pages if, for example, you are a user of the Platform or a corporate client key contact.

We may also collect your PII from third parties. This may include (but is not limited to) the collection of your PPI from:

• your employer, for example, if your employer has engaged us to provide the Platform and Springday Services to its employees;

• nursing service providers, for example, if your employer has engaged a nurse to assist with the completion of your well-being assessment;

• someone duly authorised to act on your behalf;

• where you have provided consent, from your private health insurer and/or medical or health practitioner to, for example, co-ordinate any care requirements you may have;

• recruiters we have retained, from referees you have provided in support of a job application and any service provider we may engage to conduct background checks on job applicants.

As stated above, Springday may also access data from your wearables and connected fitness devices, consumer health applications and/or health data aggregators if you chose to use them in connection with a Program or Tool available on the Platform.

3. Does Springday collect NPII?

We collect NPII using “cookies” and “action tags”.

Cookies “Cookies” are small text files that are placed on your computer in order to identify (i) your Web browser, (ii) the activities of your computer on our Website and (iii) your activity in connection with our advertisements and other marketing and promotional efforts. Cookies are used to personalise your experience on our Website (such as dynamically generating content on webpages specifically designed for you), to assist you in using the website (such as saving time by not having to reenter your name upon each visit to our Website), and to allow us to statistically monitor how you are using our Website to help us improve our online offerings. We also may use cookies to conduct marketing and promotional efforts, target certain advertisements to your browser, which may be of interest to you, or to determine the popularity of certain content.

In addition to cookies that we place on your computer, cookies may also be placed on your computer by third parties that we use to display or serve advertisements on our Website or to collect NPII for advertising-related services. In the course of serving advertisements on this Website, third party ad servers may place or recognise unique “cookies” on your browser. Neither these third parties nor their cookies collect PII on our Website, and we do not share PII with them without your permission.

You do not have to accept cookies to use our Website. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the "Help" section of the toolbar. While you are not required to accept our cookies to access our Website, if you reject cookies, certain offerings, features, or resources of our Website (may not work properly and you may experience some loss of convenience.

Action Tags

"Action tags," also known as web beacons or GIF tags, are a web technology used to help track anonymous website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of our Website, including advertisements, or email sent on our behalf, may contain action tags. Unlike cookies, action tags are not placed on your computer.

We may select and use different third parties from time to time to track website usage through action tags on our Website and on our advertisements on other websites. For example, these third parties may track anonymous website usage by setting a cookie (or reading a cookie previously placed by them) on users' computers to track the activities of users who view a web page that contains action tags. These third parties may use information about your visits to this Website and other websites in order to provide advertisements about goods and services that may be of interest to you. Periodically, upon our request, these third parties may report the anonymous data that they collect on our behalf back to us for our internal use and analysis and our treatment of this anonymous data is governed by the terms of this Privacy Policy.

By using cookies and action tags together, we are able to gain valuable information to improve Springday and measure the effectiveness of our advertising and marketing campaigns. We do not disclose any of your PII to our advertising partners through the use of cookies or action tags.

Finally, please note that advertisers and other third parties may also use their own cookies or action tags when you click on their advertisement or link to their website or service, on or from our Website. This Privacy Policy does not govern the use of cookies or action tags by advertisers or other third parties.

Log Files

We may also collect NPII through our Internet Log Files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of our Website. This information may be used to analyse trends, to administer our Website, to monitor our Website's use, and to gather general demographic information. We may link this information to PII for these and other purposes such as personalising your experience on our Website and evaluating our Website in general.

4. How does Springday use the information we collect?

If you subscribe to the Platform, complete the Wellbeing Check Tool or use other Tools or Programs available on the Platform, we may use your PII to:

• assist you to monitor and improve your health, fitness and wellbeing etc. For example, if you have completed the Wellbeing Check Tool, we will use your PII to send you an overview on your wellbeing based on your responses when completing the Wellbeing Check;

• send you details of, for example, Programs, Tools and service providers etc which may assist you with your health, fitness and wellbeing;

• manage appointments you may schedule via the Platform;

• send you direct marketing messages which we consider may be of interest to you;

• the prevention of fraud and/or identifying and investigating any suspicious use of our Website, Platform or the Springday Services;

• for our internal business and management processes, for example accounting or auditing purposes;

• for any other purpose to allow us to comply with our obligations under law; and

• for any other purposes that would reasonably be expected by you.

We may also use your PII to send you direct marketing messages about our campaigns, promotions, products and services which you might be interested in, for example, via our newsletters or email marketing communications. You may choose whether to receive these direct marketing messages from Springday.

If you do not wish to receive these direct marketing communications, you can opt-out by:

• changing your account settings by logging into your profile on the Platform or Website;

• following the unsubscribe instructions in any marketing communications we may send to you; or

• contacting us using the contact details below and informing us that you wish to opt-out.

If you create a profile on the Platform, the only information which is available to the public is your username, program, photo (if you choose to display a photo) and your points if you are participating in challenges etc. If you choose to post in the Online Community, your profile and posts will be available to those in your closed group - NOT the general public.

If you are a job applicant, employee or contractor, we will use your PII for purposes relating to your engagement, training, performance management, payroll, superannuation, health and safety, for administration and staff management purposes. Where we consider it appropriate, we may also conduct background checks (or engage a third party to do so on our behalf).

If you are a representative of a corporate client or a supplier, we will use your PII to administer and manage our relationship with your company.

The NPII we collect may be used for a variety of purposes, including but not limited to:

• help us understand who uses our Website and Platform, how they are used and to improve our Tools, Programs and the Online Community.

• perform statistical analysis of user behaviour, to analyse and evaluate issues relating to nutrition, weight loss, behaviour and fitness, and/or to evaluate and improve the Springday Services and Platform. We may link some of this information to PII for internal purposes only or to assist you in achieving your health and wellness goals.

We may provide aggregated data in respect of the Springday Services to our corporate clients so they gain insights about workplace wellbeing etc. However, no PII is provided with this data.

Where your information is no longer required for the purpose for which it was collected (for example if our agreement with your employer to provide the Platform comes to an end) and we have no legal obligation to retain the information, Springday will use reasonable endeavours to ensure that your PII is deleted, destroyed or otherwise de-identified.

5. Does Springday disclose information to third parties?

Except as set out in this Privacy Policy or as specifically agreed to by you, we will not disclose any PII we gather from you via the Platform or the Website.

We may provide your PII to your healthcare practitioner and/or insurer where you have provided consent, for example, you may permit your healthcare practitioner to monitor your fitness device tracking data, which they may access via the Platform.

Our corporate partners are not able to access the PII of their employees who use the Platform.

Third Parties Generally.

We may provide NPII (that does not allow you to be identified or contacted) to third parties, including where such information is combined with similar information of other users of the Springday Services. For example, we might inform third parties regarding the number of unique users who visit the Website or Platform, the demographic breakdown of users of Wellbeing Hubs, or the activities that visitors to our Website engage in while on our sites. The third parties to which we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners who use our Platforms, potential commercial partners, sponsors, licensees, researchers and other similar parties.

Outside Contractors.

We may engage independent contractors, vendors and suppliers (collectively, "Outside Contractors ") to provide specific services and products related to our Platform, Website and/or the

Springday Services, such as hosting and maintaining the Springday Community section of the Website, providing credit card processing and fraud screening, and developing applications for our Platforms, Website and email services. These Outside Contractors may sometimes have limited access to information collected on our Platforms and/or Website, including your PII, in the course of providing products or services to us.

From time to time, we may disclose your PII to Outside Contractors who may be located overseas for business operational, support and continuity purposes, such as our software developers based in the Philippines. Please be aware that the privacy laws in other countries might not be the same as in Australia. However, where we do disclose your personal information to overseas third parties, we will take such steps as are reasonable to ensure that your personal information is handled in accordance with this Privacy Policy.

Access to your PII by Outside Contractors is limited to the information reasonably necessary in order for the Outside Contractors to perform their limited function for us. We also require that these Outside Contractors:

a. protect the privacy of your PII consistent with this Privacy Policy, and

b. not use or disclose your PII for any purpose other than providing us with products or services for which we contracted.

Sale of Business.

We reserve the right to transfer information (including your PII) to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Springday provided that the third party agrees to adhere to the terms of this Privacy Policy.

6. Third Party Websites

Our Website may contain links to third party websites. Please be aware that these third party websites are not subject to this Privacy Policy or our privacy standards and procedures, and we are not responsible for, nor do we endorse, the content or privacy of these sites. You will need to contact these third party sites directly to obtain their privacy policies

7. How does Springday secure the information we collect?

We want your information (including PII) to remain as secure as reasonably possible. We strive to provide secure transmission of your information from your computer to our servers through industrystandard techniques.

To help ensure the integrity and privacy of the PII you provide to us via the Internet at the time you elect to become a community user or subscribe to our Website, we use Secured Socket Layer (SSL) encryption technology in transmitting such PII over the Internet to our servers. We secure the PII you provide on servers located in controlled, secure environments, protected from unauthorised access, use, or alteration.

Only employees who need access to your information to perform a specific task or function are granted access to such information. In addition, all Springday employees must abide by this Privacy Policy and are kept up-to-date on security practices.

8. Can you access, update or correct your PII?

You have a right to access and correct your PII that we hold and to have any inaccuracies in the information corrected. You also may request the erasure of your PII (eg where you have withdrawn your consent to our use of your PII) or to transfer or receive a copy of your PII in a useable format. If your PII is out-of-date or incorrect, you may inform Springday by sending us an email to privacy@myspringday.com.au or by contacting us using the Contact Details below. Depending on the PII, you may be able to correct some of your PII held by Springday in the My Profile feature of this Website.

There are some circumstances specified by law where we may refuse your request for access to and/or the correction of your personal information. However, if one of these circumstances applies, we will provide you with a written explanation of the reasons for refusal, unless it would be unreasonable to provide that notice.

Once we receive your request for access or correction, we will endeavour to respond to your request within 30 days after the request is made.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights).

9. Who do I contact if I have a privacy question or wish to lodge a complaint?

If you have any questions in relation to this Privacy Policy or your PII or if you are not satisfied with how we have handled your PII and wish to make a complaint, please contact us either by e-mail (privacy@myspringday.com.au) or by letter using the following contact details.

Or, write to our Privacy Coordinator at:

Springday Pty Ltd

Suite 145, Cicada Innovations

4 Cornwallis Street

Eveleigh NSW 2015

Attn: Privacy Coordinator

We will then investigate your complaint and endeavour to provide you with our response within a reasonable time. If, after receiving our response you still consider that your privacy complaint remains unresolved, you may then, for example, refer your concern to the Office of the Australian Information Commissioner at www.oaic.gov.au.

 

10. Changes to this Privacy Policy

Springday reserves the right to make changes to this Privacy Policy from time to time. We will publish any changes to the Privacy Policy on our Website at

url:https://corporate.myspringday.com.au/privacy . We encourage you to review the Privacy Policy regularly for updates and amendments. By continuing to use our Website or Springday Services, or by continuing to provide us with your PII after these changes have been published on our Website, you confirm your acceptance of these changes.

Contact Us

If you have any questions or comments about this Privacy Policy, please contact us using the address details below or email privacy@myspringday.com.au:

Springday Pty Ltd

Suite 145, Cicada Innovations

4 Cornwallis Street

Eveleigh NSW 2015

Attn: Privacy Coordinator

Last Updated: 31/05/2018