Alfreds Concierge Privacy Policy

1 About this privacy policy

This document sets out the policy of Alfreds Concierge Pty Ltd, its related companies and Alfreds Concierge Alfreds Concierge) relating to the privacy of your personal information (Privacy Policy). Alfreds Concierge is committed to protecting the privacy of the personal information it collects and receives. Alfreds Concierge is bound by the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth) (Act). This Privacy Policy applies to all your dealings with Alfreds Concierge, Alfreds Concierge head office or via Alfreds Concierge website (www.Alfreds Concierge.com.au). This Privacy Policy seeks to explain:

the kinds of personal information Alfreds Concierge collects & holds;

how Alfreds Concierge collects and holds your personal information;

why Alfreds Concierge collects, holds, uses and discloses your personal information;

how you may access and seek the correction of your personal information as held by Alfreds Concierge;

how you may complain about a breach of the APPs or a registered APP code (if any) that Alfreds Concierge are bound by, and how Alfreds Concierge will deal with such a complaint; and

if Alfreds Concierge is likely to disclose your personal information to overseas recipients and the countries in which such recipients are likely to be located (if it is practicable to specify those countries in this policy).

By using Alfreds Concierge website www.Alfreds Concierge.com.au, completing any membership application forms, personal trainer forms, competition entry forms and filling any forms in the franchisee recruitment process, you accept this Privacy Policy and expressly consent to Alfreds Concierge’ collection, use and disclosure of your personal information in the manner described in this Privacy Policy.

2 Your Personal Information

Alfreds Concierge only collects personal information (being information that identifies or could reasonably identify an individual) where Alfreds Concierge considers it to be reasonably necessary for Alfreds Concierge’ services, functions and activities. Alfreds Concierge collects personal information to delivery our products and service to members including in circumstances when:

processing and managing membership and franchisee applications;

facilitating members & casual members gym access;

conducting marketing activities, research & special offers;

accurately identifying who is using Alfreds Concierge’ services;

communicating with members, franchisees & website visitors to Alfreds Concierge’ website and online enquiries;

profiling our members & their interests;

operating Alfreds Concierge’ business; and / or

transferring memberships between clubs as per Alfreds Concierge transfer policy. The types of information Alfreds Concierge collects includes:

name, age, gender, date of birth & next of kin;

health information (height, weight, medical conditions);

health and goals;

license and banking details;

contact details (including phone, fax and e-mail);

views and opinions; and

responses to forms and surveys (if any).

3 Your Sensitive Information

Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record. It is Alfreds Concierge policy to only collect your sensitive information where it is reasonably necessary for Alfreds Concierge functions or activities and either you have consented or Alfreds Concierge are required or authorised under law to do so.

4 How Alfreds Concierge collects your personal information

Alfreds Concierge will solicit your personal information by lawful and fair means directly from you unless it is unreasonable or impracticable to do so.

Alfreds Concierge will collect directly personal information:

by email;

over the telephone (including calls and SMS);

via social media and over the intranet (including surveys);

by written correspondence (such as letters, faxes);

on hard copy forms (including registration forms, competition entry forms and surveys);

in person; or

through Alfreds Concierge website (online purchases, web form submission or participation in a live chat);

electronic systems such as applications and use of the club access card;

and through Alfreds Concierge’ security surveillance cameras.

Alfreds Concierge may collect information from third parties including:

parents or guardians of underage members;

the Australian Tax Office (ATO) and the Australian Securities and Investment Commission (ASIC); and

public sources (directories, membership lists, professional and trade associations, ASIC, bankruptcy or court registry searches).

5 Using your personal information

The main purposes for which Alfreds Concierge collects, holds, uses and discloses personal information are to provide services and benefits to members, and to grow Alfreds Concierge’ membership.

Alfreds Concierge collects information to service its members. Alfreds Concierge can use your information to:

process applications for memberships,

understand Alfreds Concierge’ members’ needs and requirements;

manage & run Alfreds Concierge website & social media platforms;

providing you with information about Alfreds Concierge services;

delivering or enhancing Alfreds Concierge’ products and services;

help Alfreds Concierge maximise the benefits provided to members;

any other purpose directly related to Alfreds Concierge’ business and for which you have provided consent (where it is reasonably required by law).

Alfreds Concierge’ website requires subscriptions or registrations to use certain services, functions or content. You will know what information is being collected via these processes when you complete the relevant forms and provide the required details prior to submitting the application. Alfreds Concierge will collect data relating to any transactions you carry out through Alfreds Concierge’ website and the fulfilment of your order. Alfreds Concierge may also use your data to monitor for any unauthorised use of Alfreds Concierge’ website, content or subscriptions to Alfreds Concierge’ services.

6 Purpose of collection

If Alfreds Concierge collects personal information for a purpose (the primary purpose), Alfreds Concierge will not use or disclose the information for any other purpose (the secondary purpose) unless:

you would have consented to the use or disclosure of your personal information; or
in relation to the use or disclosure of your personal information:
- you would reasonably expect Alfreds Concierge to use or disclose your information for the secondary purpose and the secondary purpose is directly related to the primary purpose;
- use or disclosure is required or authorised under Australian law or a court/tribunal;
- a permitted situation exists in relation to Alfreds Concierge’ use or disclosure of the information;
- a permitted health situation exists in relation to use or disclosure of the information; or
- Alfreds Concierge reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
If Alfreds Concierge uses or discloses your information because Alfreds Concierge reasonably believes that the use or disclosure of your information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body, Alfreds Concierge will make a written note of the use or disclosure.

7 Do you have to provide personal information?

You can refuse to provide personal information. However a refusal may mean that the service you requested is not provided or membership will be refused or forfeited.

8 Sharing your personal information

Alfreds Concierge may use and disclose personal information for related purposes to third parties. Types of organisations to whom Alfreds Concierge may disclose your personal information includes:

government bodies such as ATO, ASIC, Australian Prudential Regulatory Authority and the police or courts (as required by law);
various law enforcement agencies and governments for security, customs and immigration purposes;
banking service providers;
rewards partner program providers;
professional or government organisations; and
Alfreds Concierge’ contracted service providers including:
- information technology service providers;
- planning research and development providers;
- conference organisers;
- marketing and communications agencies;
- mailing houses, freight and courier services;
- printers & distributors of marketing material;
- debt collectors and banks;
- external advisers (recruiters, auditors & lawyers).
Alfreds Concierge does not rent, sell or exchange your personal information to third parties without your prior approval.

9 Government Identifiers

Alfreds Concierge does not adopt, use or disclose government related identifiers (such as a Medicare number or license number) as Alfreds Concierge’ own identifier for you unless:

it’s required/authorised by law or court/tribunal order;
it’s reasonably necessary to verify your identity;
it’s reasonably necessary to fulfil Alfreds Concierge’ obligations; or
Alfreds Concierge reasonably believes it is reasonably necessary for one or more enforcement related activities.

10 Cookies

To improve Alfreds Concierge’ services, Alfreds Concierge sometimes collects de-identified information from web users. The information collected does not identify an individual but does help Alfreds Concierge to analyse and improve its web services. When you visit Alfreds Concierge’ website, a record of your visit is logged and the following data is supplied by your browser:

your IP address and/or domain name;
your operating system (type of browser & platform);
the date, time and length of your visit; and
the resources you accessed or downloaded.

Alfreds Concierge uses this information to customise the website for visitors and to collect data for analysis, quality control, administration and improving the website. It is not used for any other purpose. Aggregated data may be shared with third parties.

You can stop your browser from accepting new cookies or disable cookies altogether by changing your browser preferences.

11 Links to other websites

Links to third party websites that Alfreds Concierge does not operate or control are provided for your convenience. Alfreds Concierge is not responsible for the privacy or security practices of those websites. Third party websites should have their own privacy and security policies which Alfreds Concierge encourages you to read before supplying any personal information to them.

12 Direct Marketing

If Alfreds Concierge holds your information, Alfreds Concierge may use or disclose that information (other than sensitive information) for direct marketing if:

Alfreds Concierge collected the information from you; and
you would reasonably expect Alfreds Concierge to use or disclose the information for that purpose; and
Alfreds Concierge provided you with a simple way to opt out of receiving direct marketing from Alfreds Concierge; and
you have not made such an opt out request to Alfreds Concierge. Alfreds Concierge may also use or disclose your information (other than sensitive information) for direct marketing if:
Alfreds Concierge collected the information from you and you would not reasonably expect Alfreds Concierge to use or disclose the information for that purpose or someone other than you; and
either:
- you have consented to the use or disclosure of the information for that purpose; or
- it is impracticable to obtain that consent; and
Alfreds Concierge provided you with a simple way to opt out of receiving direct marketing from Alfreds Concierge; and
in each direct marketing communication with you:
- Alfreds Concierge includes a prominent statement that you can request to opt out; or
- Alfreds Concierge otherwise draws your attention to the fact that you can request to opt out; and
- you have not made such a request to Alfreds Concierge.

Alfreds Concierge can use or disclose your sensitive information for the purpose of direct marketing if you have consented to the use or disclosure of that information for direct marketing. Alfreds Concierge may also use or disclose your personal information for direct marketing if:

Alfreds Concierge are a contracted service provider for a Commonwealth contract; and
Alfreds Concierge collected your information in order to meet an obligation under that contract; and
the use or disclosure is necessary to meet (directly or indirectly) such an obligation.

If Alfreds Concierge has collected the personal information that Alfreds Concierge used to send you direct marketing material from a third party, you can ask Alfreds Concierge to notify you of its source of information. It is Alfreds Concierge’ policy is to do so unless it is unreasonable or impracticable.

13 How to opt out of direct marketing

If Alfreds Concierge uses or discloses your personal information for the purpose of direct marketing, you may request not to receive direct marketing communications from Alfreds Concierge.

If Alfreds Concierge uses or discloses your personal information for the purpose of facilitating direct marketing by other organisations, you may request that Alfreds Concierge does not use or disclose your information for this purpose.

Alfreds Concierge will give effect to your request not to receive direct marketing from Alfreds Concierge or an entity facilitated by Alfreds Concierge within a reasonable time after the request is made.

14 Protecting your personal information

Alfreds Concierge stores information in different ways, including paper and electronic form. Alfreds Concierge takes reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure including:

secure password protected databases for storage;
confidentiality requirements of staff;
security firewalls for access to Alfreds Concierge’ systems;
servers kept at a secure location with limited access;
document storage security requirements;
granting access only to verified individuals;
access controls for Alfreds Concierge’ buildings;
limited the provision of personal information to third parties and subject to guarantees about use; and
training staff to deal with the information.

Alfreds Concierge cannot guarantee that personal information will be protected against unauthorized access or misuse and Alfreds Concierge does not accept any liability for the improper actions of unauthorised third parties. Alfreds Concierge will retain your personal information for as long as necessary to fulfil Alfreds Concierge’ obligations to you, to protect its legal interests, to comply with laws or as otherwise stated to you when Alfreds Concierge collects your personal information. Once Alfreds Concierge is no longer required to retain your personal information, Alfreds Concierge will take reasonable steps to destroy your personal information or to ensure that your personal information is de-identified. 15 Disclosing your personal information overseas Alfreds Concierge and Alfreds Concierge group entities may disclose your personal information to other third party service providers operating outside Australia who work with Alfreds Concierge or one of Alfreds Concierge’ suppliers, agents, or partners. Alfreds Concierge may also store your personal information on servers based overseas or in the “cloud” or other types of networked or electronic storage. Before disclosing your personal information to an overseas third party, Alfreds Concierge will first take reasonable steps to ensure that the overseas recipient:

does not breach the Australian Privacy Principles in relation to your personal information; or
the recipient of the information is subject to a law, or binding scheme, that has the effect of protecting your personal information in a way that is substantially similar to the way in which the Australian Privacy Principles protect the information.

Personal information may be disclosed by Alfreds Concierge to other Alfreds Concierge entities and third parties in jurisdictions including: Australia, New Zealand, United States of America and the Netherlands. The European Commission has recognized each of these countries as providing adequate protection of personal information.

To make it easy for you to deal with Alfreds Concierge and other Alfreds Concierge entities and provide you with a more personal and consistent experience, Alfreds Concierge may exchange and combine personal information with other Alfreds Concierge entities for the purposes described in this Privacy Policy.

If your personal information is collected using a document that references this Privacy Policy, you are taken to consent to the disclosure, transfer, storing or processing of your personal information outside of Australia.

You acknowledge and understand that by providing such consent:

Alfreds Concierge will not be required to take steps as are reasonable in the circumstances to ensure that such third parties comply with the APPs;
if the overseas recipient handles your personal information in breach of the APPs:
- Alfreds Concierge will not be liable under the Act; and
- you will not be able to seek redress under Act.
the overseas recipient may not be subject to any privacy law or principles similar to the APPs;
- you may be unable to seek redress overseas;
- the overseas recipient is subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

If you withdraw consent, Alfreds Concierge will not rely on this consent when dealing with your personal information going forward.

16 Anonymity

You have the option of not identifying yourself or using a pseudonym when dealing with Alfreds Concierge provided that is it lawful and practicable.

Alfreds Concierge will try to accommodate a request for anonymity if possible. However, your right to anonymity does not apply in relation to a matter if:

Alfreds Concierge is required/authorised by law or court/tribunal order to deal with identified individuals; or
it is impracticable for Alfreds Concierge to deal with individuals who have not identified themselves.

It is Alfreds Concierge’ policy to enable you to access Alfreds Concierge’ website and make general phone queries without having to identify yourself and to enable you to respond to Alfreds Concierge’ surveys anonymously. In some cases however, if you don't provide Alfreds Concierge with your personal information when requested, Alfreds Concierge may not be able to respond to your request or provide you with our service. For example, you must identify yourself to become a Alfreds Concierge member or franchisee.

17 Accessing to your personal information

You have the right, upon request, to access any of Alfreds Concierge’ records containing your personal information. To request access to your personal information please contact the Privacy Officer, set out at the end of this Policy.

Alfreds Concierge will respond to your request to access your personal information within a reasonable period of time.

On the basis that it is reasonable and practicable to do so, Alfreds Concierge will give you access to the information requested.

If Alfreds Concierge refuses your request to access personal information, Alfreds Concierge will provide a written notice setting out the reasons for the refusal & how you can complain about the refusal.

Reasons for a refusal may include if it:

poses a serious threat to the life, health or safety;
would have unreasonable impact on privacy of others;
is frivolous or vexatious;
relates to legal proceedings;
reveals Alfreds Concierge’ 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.

When you make a request to access personal information, Alfreds Concierge will require you to provide some form of identification (such as a driver's licence or passport) so Alfreds Concierge can verify that you are the person to whom the information relates.

18 Help Alfreds Concierge keep your personal information accurate

Alfreds Concierge will take reasonable steps to ensure Alfreds Concierge’ records of personal information are accurate, up to date and complete.

However, the accuracy of information depends to a large extent on the information you provide. If you do not give Alfreds Concierge all the personal information Alfreds Concierge may require, or the personal information provided is inaccurate or incomplete, then the products, services and information Alfreds Concierge provide may be affected.

If you think there is something wrong with the information Alfreds Concierge holds about you please contact the Privacy Officer to:

let Alfreds Concierge know if there are any errors; and
keep Alfreds Concierge up-to-date with any changes, and Alfreds Concierge will try to correct your personal information.

Alfreds Concierge will respond to your request to correct your personal information and in a reasonable period of time. If Alfreds Concierge refuses your request, Alfreds Concierge will provide you with a written notice setting out the reasons for the refusal and mechanisms available to complain about the refusal.

If Alfreds Concierge refuses to correct your personal information, you may request that Alfreds Concierge associate your information with a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. Alfreds Concierge will take reasonable steps to make the statement visible to users of your personal information.

If Alfreds Concierge does correct your personal information and Alfreds Concierge has previously disclosed your personal information to a third party, upon your request, Alfreds Concierge will notify that third party of the correction unless it is impracticable or unlawful to do so.

19 Resolving your privacy issues

If you have any issues you wish to discuss with Alfreds Concierge or if you’re concerned about how Alfreds Concierge has collected or managed your personal information please contact the Privacy Officer.

For information about privacy or if your concerns are not resolved, contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.

20 Changes and access to this privacy policy

Alfreds Concierge may, from time to time, review and update this privacy policy to take account of new laws and changes to Alfreds Concierge’ operations. Changes to this Privacy Policy will not affect Alfreds Concierge’ use of previously provided information.

This Privacy Policy is available on Alfreds Concierge’ website at www.Alfreds Concierge.com.au. A printed Privacy Policy can be obtained free of charge by contacting the Privacy Officer.