Privacy Policy & Data Collection Statement

This privacy policy is for the WillWay (Australia) Pty Ltd ACN 067 558 356 and the WillWay Wellness Website. This website exists to provide action-oriented ‘doers’ with resources to self-assess, self-inform, and self-adjust to address the causes, symptoms, and impacts of stress on their physical, emotional, and mental wellness. These policies do not extend to websites to which our site has links.

WillWay (Australia) Pty Ltd operated for decades as a specialist personal and organisational change management consultancy; and now as an online resource on knowledge, methods, and tools for easier implementation of change and management of the accompanying issues of stress, distress, stress reduction, and emotional resilience.

This Privacy Policy is the official privacy policy of WillWay (Australia) Pty Ltd and its websites. It applies to all personal information collected by WillWay (Australia) Pty Ltd, including via any and all related WillWay (Australia) Pty Ltd website, social media page, internal website or intranet (each a Website); any WillWay (Australia) Pty Ltd mobile or tablet application (each an Application); and from an individual via any other means, including physically or electronically (together, the Collection Channels).

NB. Policy statements relating to financial transactions are in abeyance on this pilot website. Policies are provided here for reference as to their application once the enlarged website is trading.

We collect information only by fair and lawful means where it is reasonable and practicable to do so. We do so to conduct our organisation, effectively deliver our services, to provide accurate information to you, to market our goods, and to meet our legal obligations.

  1. In this policy, we explain how and why we collect your personal information, how we use it and disclose it, and what controls you have over our use of it. We appreciate that you may have certain concerns about how your personal information is collected, used, and shared. We can assure you that we will always handle your personal information securely and carefully with no disclosure to third parties unless specifically required to do so by law as is set out below. Among other things, we comply with all applicable Australian privacy laws including the Australian Privacy Principles.
  1. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

Anonymity and Pseudonymity

  1. You have the option of dealing with WillWay (Australia) Pty Ltd anonymously. However, this only applies where it is practicable for WillWay (Australia) Pty Ltd to deal with you acting anonymously or under a pseudonym, such as a general enquiry.

Collection of Information

  1. Throughout this privacy policy, we refer to “personal information”, which means information or an opinion about an identified individual, or a reasonably identifiable individual, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Your first and last name, date of birth, gender, home address, contact telephone number, mobile telephone number, email address, and employment details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.
  1. Some information provided to us by customers might be considered to be personal information. We will only collect such personal information if it is necessary for one of our functions or activities. The kinds of personal information that WillWay (Australia) Pty Ltd collects are set out below.

Information that you provide to us

  1. We collect personal information that you provide directly to us, such as when you register with us, whether for email notifications, or purchase of our support services. This information may include:
    1. your name;
    2. your contact details including your email address, residential address, phone number, and social media handles;
    3. more detailed contact preferences;
    4. information regarding your experiences with our products and services;
    5. financial information, including credit card and payment details.
  2. Financial information that is collected via the website is used by WillWay (Australia) Pty Ltd to bill you for products and services. Any financial information that is collected is for transaction approval and funds transfer. The financial information we collect from you is kept securely and held on secure servers in controlled facilities.

Information that we collect from your use of our Websites and Application

  1. When you use a Website or Application, we may also collect personal information about you in the following general categories:
    1. Transaction information: we collect your transaction details when you place an order, including the products you have ordered, the date and time of your order, and the amount charged.
    2. Usage and preferences: We collect information about how you interact with our Websites or Applications, including the pages you visit, your preferences, and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you.
    3. Device information: We may collect information about your device, such as the hardware model, operating system, preferred language, unique device identifier and mobile network.
    4. Other information: We may also collect and log information such as your IP address, access dates and times, browser type, and pages visited when you interact with a Website or Application.

Information that we collect from third parties

  1. In addition to the information listed above, in some cases, we may collect personal information about you from legitimate third party sources, including social media sites and list broker and other data providers that share data in circumstances where it is lawful and/or they have your permission to do so. This may include:

When you choose to create an account or register for a product or service via a Website or Application using a social media platform such as Facebook;

When a third party has your consent to disclose your personal information to us, such as when you enter a competition or promotion administered by a third party on our behalf;

  1. How WillWay (Australia) Pty Ltd collects, uses and discloses personal information
  1. At or before the time the personal information is collected by us via a particular Collection Channel, we will take reasonable steps to provide you with a collection statement to ensure that you are made aware of who we are, the fact that you can gain access to the information held about you, the purpose of the collection, the type(s) of organisations to which we usually disclose the information collected about you, any laws requiring the collection of the information and the main consequences for you if all or part of the information is not collected. We will not collect or monitor any personal information about you without your consent, including as provided in this privacy policy.

Active information collection

  1. In particular, WillWay (Australia) Pty Ltd will collect your personal information from you in the following situations:
    1. If you contact WillWay (Australia) Pty Ltd, we may keep a record of that correspondence;
    2. When you participate in any online questionnaires and self-assessment tests.
    3. When you apply for and/or establish and/or access an account or order a product;
    4. When you conduct financial transactions with WillWay (Australia) Pty Ltd.
    5. When you submit your e-mail address via a Website or Application or provide us with personal information via any medium, including a Website or Application;
    6. When you place an order via a Website or Application to purchase goods, in which case we may require you to provide us with contact information including your name, address, telephone number or email address and financial information (such as credit card details);
    7. When you interact with a Website or Application for a specific purpose; and
    8. When you use or browse a Website, or Application generally.

Cookies and Passive Information Collection

  1. As you navigate through our Websites and access our Applications, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, and clickstream data). For example, we may collect information about matters including but not limited to the date, time, and duration of visits and which pages of a Website or Application are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website or Application is accessed via links in an email or another electronic message we have sent or where we are able to uniquely identify the device or user accessing a Website or Application, such as when you are logged into an account.
  2. We may combine your anonymous or personal visitor session information or other information collected through tracking technologies with other personal information collected from you from time to time via our Collection Channels, to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website or Application via links in an email we have sent and/or by accessing a Website or Application where you have identified yourself, you consent to collection of such information where it is personal information.

Platform and Browser Permissions

  1. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. To learn more about cookies and how to specify your preferences, please search for “cookie” in the “Help” portion of your browser.
  2. Mobile platforms such as iOS and Android generally define certain types of information or data that applications cannot access without your consent. Each platform has its own permissions system for obtaining your consent. For example, the iOS platform generally alerts you the first time a WillWay (Australia) Pty Ltd Application wants permission to access certain types of data, such as location services and, will let you choose whether or not to consent to that request. Android devices will generally notify you of the permissions that a WillWay (Australia) Pty Ltd Application seeks before you first use the Application, and your use of the Application constitutes your consent. For iOS devices, you can generally manage your platform level permissions via the Settings section on your device. For Android devices, you can usually manage your platform level permissions.

Use of information collected and disclosure of personal information to others

  1. We collect such personal information so that we can provide you with a great service. We also need this information to deliver products and services to you in the future, complete transactions on your behalf, and to better understand your requirements and preferences. Personal information collected will be used for the following primary purposes:
    1. For the purposes stated on a particular Collection Channel;
    2. To maintain functionality of the Website, including the provision of information to you relating to the content available on the Website and e-commerce transactions conducted via the Website;
    3. For testing purposes;
    4. To fulfill obligations in respect of any upload terms of use, sale and purchase contract and/or any other contract between you and WillWay (Australia) Pty Ltd;
    5. To send you any technical, administrative or legal notices important to our Websites or Applications;
    6. To provide you with information about your transactions (including uploading of, access to, and receipt of, content on a Website or Application and purchase transactions undertaken on a Website or Application) and about content, services and products;
    7. To provide marketing materials, events, special offers, competitions, and promotions via any medium including mail, telephone, email, SMS or any other form of electronic, emerging, digital or conventional communications channel;
    8. To maintain our relationship with you;
    9. To respond to enquiries;
    10. To obtain opinions or comments about products and/or services and to conduct other market research and development (including to record statistical data for technical and marketing analysis);
    11. to combine with other personal information, we hold about you and to assess which of our products and services are most likely to be of interest to you;
    12. to provide you with relevant update information when you browse our Websites;
    13. to provide, maintain and improve our products and services;
    14. to customise a Website or Application, based on your preferences; and
    15. to share with your social media communities, to the extent allowed by you.
  1. For the purposes described above, personal information may be shared with our web hosting provider and not provided ot any other organisation or person without your advance knowledge and permission.
  1. Failure to provide personal information may result in WillWay (Australia) Pty Ltd being unable to provide you with the products or services requested by you, provide you with certain content and information.
  1. In order to operate a Website or Application or deliver a product or service (including, for example, processing of credit card payments), personal information may also be shared with selected service providers and/or other trusted third parties. Selected service providers and/or other trusted third parties may be engaged to perform a variety of functions, such as data storage, fulfilling orders, conducting market research, processing credit card payments, and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions. However, these companies may only use such personal information for the purpose of performing that function and may not use it for any other purpose.
  1. We may use or disclose personal information held about an individual for the primary purpose for which it is collected – that is, to carry on our business and provide services to our customers. We may also use such information for a purpose related to the primary purpose of collection and where you would reasonably expect that we would use the information in such a way. This information is only disclosed to persons outside our business in the circumstances set out in this policy or as otherwise notified to you at the time of collection of the information, or with your permission.
  1. In addition, we are permitted to use or disclose personal information held about you to another person, entity, government authority, or organisation:
    1. Where you have consented to the use or disclosure;
    2. Where we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone’s health or safety or the public’s health or safety;
    3. Where we reasonably suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
    4. Where such use or disclosure is required under or authorised by law (for example, to comply with a subpoena, a warrant or other order of a court or legal process);
    5. Where we reasonably believe that the use or disclosure is necessary for prevention, investigation, prosecution and punishment of crimes or wrongdoings or the preparation for, conduct of, proceedings before any court or tribunal or the implementation of the orders of a court or tribunal by or on behalf of an enforcement body.
  1. Where a permitted general or health situation exemption applies under the Federal Privacy Act 1988

We will not sell, disclose, or transfer your information to anyone, whether person or organisation, in any shape or form at any time.

Site Research Use

By disclosing personal information or other data on the WillWay (Australia) Pty Ltd website, for example, by completing surveys or posting feedback, you acknowledge that the data you submit may be used by us for research and evaluation purposes. Any information collected in this way will be de-identified before analysis, and any identifying data will be destroyed or permanently deleted at your request at any time, but definitely, when you cease to subscribe to the site. Research and evaluation activities will be subject to ethics approval.

Storage and Disposal of Information

We take reasonable steps to protect your information against misuse, interference, loss, unauthorised access, modification, and disclosure. The protective steps we take include:

  • confidentiality requirements of our employees and subcontractors;
  • limiting access to information to employees who need to use the information;
  • educating our employees in relation to obligations under the relevant Federal, State and Territory Acts and legislation and using ethical codes of conduct for health practitioners as a model to follow;
  • document and file storage security policies;
  • security measures for restricted access to our systems; and
  • deletion, destruction, or de-identification of information where it is no longer required by both you and us.

Access To Information

You are entitled to access your information held by us.

If you wish to access your information, you must lodge a written request for access by contacting us via our website email.

Your request must contain your name and address, the contact number you used to access our services, sufficiently identify the information you wish to access, and provide your authority if requesting information on behalf of another person.

We may charge a fee to cover our reasonable costs in meeting an access request. You will be provided with access to the information within 30 days of the request (unless unusual circumstances apply).

We are not required to give you access to your information if:

  • it would be unlawful to do so, or
  • denying access is required or authorised, by an Australian law or a court/tribunal order; or,
  • to do so would likely prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

If we do not give you access to your information, you will receive written notice that explains the reason for the refusal.

Your Internet Use

You are aware that there are risks of breach of privacy associated with use of the internet. We operate on the basis that you take adequate action to preserve the privacy of your own information and communication with the The Good News Stress Website. Such issues are beyond our control and responsibility.

Complaints

If you do have a privacy complaint and not consider that your privacy complaint has been adequately dealt with by us, you may make a further complaint to the following commissions;

  • Office of the Australian Information Commissioner, which has complaint handling responsibilities under the Federal Privacy Act,
  • the Victorian Health Complaints Commissioner, which has complaint handling responsibilities under the Health Complaints Act 2016 (Vic)

Updates to Privacy Policy

WillWay (Australia) Pty Ltd may amend this Policy at any time by posting the updated terms on the Good News About Stress website. The amended terms take effect when you access the Good News Stress Website or after 30 days, whichever is sooner.

Further Information

If you have any questions about privacy-related issues, please contact .us immediately.

For further information about privacy, the protection of privacy and credit reporting can also be found on the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

Privacy Act 1988 (National) – includes Australian Privacy Principles

  • Privacy Act 1988 Commonwealth
  • Privacy Amendment Act 2012 Commonwealth

Terms

Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  • whether the information or opinion is true, or not; and
  • whether the information or opinion is recorded in a material form, or not.

Privacy Act means the Privacy Act 1988 (Cth) as amended from time to time.

Sensitive Information is defined in the Privacy Act to include things such as race, sexual orientation, political opinions, members of a trade association or trade union, criminal record, or health information.

 

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