Better Health Products (Aust) Pty Ltd respects the privacy of your personal information and is committed to ensuring its proper collection, storage, use, and disclosure. This policy is intended to explain some of the key processes and procedures that we have implemented to manage your personal information, to protect your privacy, and to comply with the Privacy Act 1988, the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (“Act”) and the Australian Privacy Principles.

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

This policy applies to personal information collected by Better Health Products (Aust) Pty Ltd (“we”, “our” and “us”) and gives a broad overview of our policies concerning how we safeguard your privacy but if you require further information, you are welcome to contact us.

What sorts of personal information do we collect?

We will only collect from you information that is necessary and relevant to our relationship with you, including to enable us to provide you the best possible service and customer experience.

Depending on the exact nature of our relationship with you, we may request that you provide some or all of the following information:

•  information that we may require to initially identify you, including your name, home address, and your date of birth;
•  information that we can use to contact you, including your telephone number, mobile number, email address, work address, mailing address;
•  information we may require to confirm your identity when you are considering a finance or credit arrangement, including your date of birth, driver’s licence number, passport details, business name, Medicare card, pensioners customer reference number (CRN);
•  information that may assist us to confirm your financial position or credit history when you are considering a finance or credit arrangement, including your credit card details, bank details, purchase history or transaction details, and loan and credit information where finance arrangements apply.

It would be very unusual for us to need to collect all or even most of the above information from you however the information we will require will depend on the specific service or services that we are providing to you. We will only collect personal information from you that we reasonably require to satisfactorily perform the services that you require from us.

The Act places restrictions on us collecting sensitive information about you (which includes information about your religion, political views, ethnicity, criminal records, and sexual preferences). Generally, we will not collect this type of information, however, we may need to collect some sensitive information if you are applying for a job with us, and you have provided us with your consent to do so.

Why do we require your personal information?

There are various reasons why we might need to collect, hold, use or disclose your personal information and this will depend upon the specific services that we are providing to you but we will tell you the main reason for asking for your personal information at the time when we ask you to provide it.

Usually, the main reason that we will need to collect your personal information will be relating to a service that we are providing to you or are about to provide to you and for contacting you concerning those services. Our main services include the sale and delivery of goods; providing information and responding to queries concerning our goods and services; facilitating online chat; coordinating the provision of credit; processing of warranties and coordinating the installation of goods.

There is no obligation for you to provide us with any of your personal information but if you choose not to provide us with your personal information, we may not be able to provide the information, goods, or services that you require.

How do we collect your personal information?

How we collect your personal information will depend on the nature of the service that we are providing to you.

We may collect your personal information:

1. directly from you, either in person or over the phone with our consultants;
2. when you place an order via the Website;
3. when you interact with our Facebook page;
4. when you email or direct message one of our consultants; or
5. from other sources.

We will always collect your personal information directly from you unless it is impracticable to do so. This would usually be done through the Website when you elect to disclose your personal information to us for a particular purpose.

Where we are collecting your personal information, we will remind you of the following at the time of collecting your personal information:

1. our details, including our contact details;
2. that we are collecting your information and the reasons why we are collecting your information;
3. if the collection is required or authorised by law, the details of the law, court, or tribunal order;
4. what happens if we cannot collect your personal information;
5. any third parties to whom we may disclose the personal information;
6. how you can access and correct your personal information;
7. how you can complain about any breach of the APPs and how we will handle any such complaints; and
8. whether your personal information is likely to be disclosed to anyone overseas and if practicable, the countries in which those recipients are located.

Collecting and disclosing personal information about others

Wherever possible, we will collect personal information directly from the relevant individual to whom that information relates.

You represent and warrant to us that where you provide personal information to us about another person:

• you are authorised to provide that information to us;
• you have obtained the express consent of the individual to disclose their personal information to us for its relevant use, including for use in our business and to provide our services;
• you have complied with the APPs in collecting that personal information, including by making all relevant notifications required under APP 5; and
• you have informed that person about the contents of this privacy policy including who we are, how we use and disclose personal information, and that they can gain access to, and correct, that information.

How do we use or disclose your personal information?

We may use and disclose your personal information for the purposes for which it was collected or for a related purpose such as:

• to set up and activate an account with Better Health Products;
• to consider your request for a product or service;
• to enable us to provide a product or a service to you;
• to coordinate delivery of your goods;
• to facilitate and process your orders and payments;
• to carry out or respond to your queries or requests;
• to provide information to you that you have requested;
• to provide additional information to you as requested by you and to respond to your queries about our products;
• to facilitate online chat;
• to any third party suppliers of our goods or services, including third-party application owners or licensors;
• to any third party credit provider to facilitate the provision of credit to you as required;
• for regulatory reporting and compliance with our legal obligations;
• to relevant third parties to undertake fraud checks;
• to various regulatory bodies and law enforcement officials and agencies to protect against fraud and for related security purposes; or
• to facilitate product reviews and to seek your feedback about particular products, customer satisfaction, and our relationship with you, and to manage any customer complaints.

By agreeing to accept the terms of this privacy policy or by providing your personal information to us, or both, you are taken to have consented to the use and disclosure of your personal information for the above purposes.

At the time that we collect your personal information, we will make it clear to you why we are collecting your information, including through this privacy policy where appropriate. We will not use your personal information for any other purpose without your consent or where we do use your information for another purpose, it will either be for a purpose which we believe is related to the purpose for which you first provided us with the information or for a purpose which you would expect.

Other than as outlined in this privacy policy or in any notice provided to you at the time of collecting your personal information, we will not disclose your personal information without your consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.

Do we share your personal information with others?

We may share your personal information with other companies that are related to Better Health Products (Aust) Pty Ltd or with any Recipient Party. By agreeing to accept the terms of this privacy policy or by providing your personal information to us, or both, you consent to your personal information being shared with our related entities and with any one or more of the Recipient Parties.

We deal with third-party service providers who may assist us with a variety of functions including delivery, security, insurance, professional advisory (including legal, accounting, and auditing advice), banking, payment processing, facilitating credit arrangements, credit reporting, fraud checks, data storage, information processing, order tracking, product reviews, responding to customer queries and complaints or technology services. By agreeing to accept the terms of this privacy policy or by providing your personal information to us, or both, you are taken to have consented to us disclosing your personal information to our third-party service providers.

Where we engage third-party service providers to perform services for us, those third parties may be required to handle or deal with your personal information. Under these circumstances, those third parties must safeguard this information and must only use it for the purposes for which it was supplied and we will make all reasonable enquiries to try to ensure that this is the case.

Wherever possible, we will limit the information provided to independent third parties to that information required for those third parties to properly perform their functions. Further, our contracts with these third parties will always require the third parties to comply with the APPs (or equivalent standards).

How do we store your personal information?

We have implemented appropriate processes and techniques (including physical security such as locks and security systems and computer and network security, including firewalls and passwords) to protect personal information from loss, misuse and interference and from unauthorised access, modification or disclosure. Also, access to your personal information is limited to those who specifically need it to conduct their responsibilities.

We and our third-party service providers take all necessary steps to destroy or permanently de-identify your personal information where it is no longer required and to protect your personal information from loss, misuse and interference and from unauthorised access, modification or disclosure.

While care is taken to protect your personal information on the Website, unfortunately, no data transmission over the Internet is guaranteed as 100% secure. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email as we have no way of protecting that information until it reaches us. Once we receive your personal information, we are required to protect it under the Act.

Maintaining your personal information

We take reasonable steps to ensure that:

• the information that we collect about you is accurate, complete, and up-to-date at the time of collection;
• when we use your personal information, it is accurate, up-to-date, complete, and accurate at the time of use; and
• if we disclose your personal information, it is accurate, up-to-date, complete, and accurate at the time of disclosure.

How can you access 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 by email, at shane@betterhealthproducts.com.au, with confirmation of your identity.

There are some limited circumstances in which we may not be able to provide you with access to your personal information when requested. Such circumstances might include:

• where access would pose a serious threat to the life, health, or safety of another person, or
• where such access would unreasonably impact the privacy of others.

Where you request access to your personal information, we will respond to any such request within a reasonable period after the request is made and if possible, we will provide you with access to your information in the manner requested by you, if specified. In any event, we will take all reasonable steps to give you access to your information in a way that meets your needs.

If we deny you access to your personal information for any reason, or if we are unable to provide you with access to your information in the manner requested by you, then we will provide you with a written notice confirming:

• the reason for such refusal; and
• the procedure to complain about the refusal.

We may recover from you our reasonable costs of supplying you with access to your personal information but we will not charge you for any request you might make to access your information.

How can you seek to correct your personal information?

We do what we can to ensure that the information we hold about you is accurate, complete, up-to-date, relevant, and not misleading. To assist us to do this, please ensure that you provide us with correct information at the time you provide it to us and immediately inform us if your details change at any time. If we are concerned that any of your information is inaccurate, incomplete, out-of-date, irrelevant, or misleading, or if you request that we correct any of your information, then we will take all reasonable steps to correct the information to ensure that it is accurate, complete, up-to-date, relevant and not misleading in the context of the purpose for which it is held.

If we correct any of your personal information and that information has previously been disclosed to another entity that is required to comply with the APPs, then, upon your request to do so, we will take reasonable steps to notify that other entity of the correction unless such notification is impracticable or unlawful.

If we refuse to correct your personal information following a request by you to do so, then we will provide you with a written notice confirming:

• the reason for such refusal; and
• the procedure to complain about the refusal.

If we refuse to correct your personal information following a request by you to do so and you request that we associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant, or misleading then we will take reasonable steps to associate the statement with the information so that the statement is apparent to users of the information.

We will respond to any requests regarding the correction of your personal information within a reasonable period after the request is made.

We will not charge you for any request to correct your personal information, nor will we pass on to you any costs incurred by us in correcting your personal information or for associating a statement with your personal information.

What if you want to make a complaint about some aspect of our privacy procedures?

We are committed to maintaining and protecting your privacy but it is possible that in limited circumstances, mistakes might be made. If you are concerned with the way your personal information has been handled then you are entitled to make a complaint. If you would like to lodge a complaint, please contact us through email.

If your personal information has not been handled appropriately, we will do our best to remedy your concerns as quickly as possible, including by acknowledging receipt of your complaint within 48 hours and trying to resolve the complaint within 10 working days. Where this is not possible, we will contact you within this period to let you know an anticipated time frame within which your complaint will be resolved.

If your complaint is not satisfactorily resolved, you may approach an external dispute resolution service or apply to the Office of the Australian Information Commissioner (“OAIC”) to have the complaint heard and determined.

Changes to this policy

From time to time it may be necessary for us to review and revise this privacy policy. We reserve the right to change our privacy policy at any time.

How can you contact us?

Please find below our contact details. Please do not hesitate to contact us relating to any privacy-related concerns and we will do our best to address any such concerns thoroughly and promptly.

If it is practical to do so, you can contact us without identifying yourself. However, if you choose not to identify yourself, it may be more difficult for us to assist you with your enquiry. This will depend on the nature of your enquiry.

Shane Blackley,
E-mail address: shane@betterhealthproducts.com.au

Phone: +61 0457 080 054

Erin Blackley,

Email address: erin@betterhealthproducts.com.au

Phone: +61 0403 317 548

Please note that the Act contains certain exemptions that may permit us to use your personal information in a particular way if specific circumstances arise. Any such exemptions under the Act will take priority over this privacy policy to the extent of any inconsistencies.