Privacy Policy

Wellthly Pty Ltd (“Wellthly”, “we”, “us” or “our”) is committed to protecting your privacy and complying with all privacy and data protection laws, principles and regulations that apply in Australia, and this Privacy Policy has been specifically tailored to comply with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles and HIPAA compliant standards.

This Privacy Policy describes our policies and procedures on the collection, holding, use and disclosure of your personal information. This Privacy Policy applies to all your dealings with Wellthly.

What is personal information?

When used in this Policy, “personal information” means any information or opinion relating to an identified or identifiable individual.

In general terms, it is information that can be used to personally identify you such as your name, address, telephone number, email address, profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect?

As a customer of Wellthly, certain personal information will be required to establish and maintain your record, and to provide services to you. We may collect the following types of personal information relating to you:

identification information such as your name, date of birth, contact phone details, residential, postal and email addresses, or gender.
demographic information and unique identifiers in order to provide you with a more personalised experience or to verify your passwords.

How do we collect personal information?

We may collect your personal information in several ways, including:

when you email, fax, phone or write to us;
have contact with us in person;
participate in public or closed surveys, questionnaires or conference events;
register for face-to-face or digital events (such as webinars); and
interact with us online, including through our websites, email, webchats, mobile applications and social media channels (such as Facebook, Twitter, YouTube, Instagram or LinkedIn – these social media channels will also handle your personal information for their own purposes and have their own privacy policies);

In some cases, we may also collect your personal information through the use of “cookies”. When you access one of our websites, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer or internet enabled device. This allows us to recognise your computer or internet enabled device, and whether you have already registered and greet you each time you visit our website/s. It also enables us to keep track of services you view so that, if you consent, we can send you news about those services. We also use cookies to measure traffic and engagement patterns, to determine which areas of our website have been visited and to measure overall, aggregate transaction patterns. We use this to research our website visitor’s habits and what they are looking for and accessing, so that we can continually improve our services, programs, content and resources. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

What happens if we receive unsolicited personal information?

If we receive personal information that we did not take any active steps to collect, we will determine whether we would have been permitted to collect that information as part of providing our products and services in accordance with the law. We will destroy or de-identify unsolicited personal information that we would not collect as part of providing our products or services if it is lawful to do so. If the information is of the type that we would ordinarily collect to provide our products or services, we will manage that information in accordance with this Privacy Policy.

Why do we collect your personal information?

We will generally explain at the time we collect your personal information the purposes for which we will use it. We will only ever use your personal information for the purpose that we collected it or as otherwise set out in this Privacy Policy. We may collect, hold, use and/or disclose your personal information for the following purposes:

to provide you with our products and services;
to update our records and keep contact details up to date;
to provide you with services and information appropriate to your needs;
to answer your enquiries and to provide information to you about our services;
to provide analysis of information for product development and marketing purposes;
to develop and improve our products and services;
to perform administrative functions and for other internal purposes;
for information technology maintenance and development;
to investigate and resolve complaints relating to services provided by/or on behalf of Wellthly;
to comply with any law or legislative requirements;
for any purpose required or authorised by law; and
for any other purpose for which you have given your consent.

Do we use your personal information for direct marketing?

We may use your personal information to send you direct marketing communication and information about our services and products, and other related services and products if we have your permission or a legitimate interest in doing so. If at any time you no longer wish to receive this information, you can request to “opt out” from receiving this information by contacting us via the “Contact Us” button at the top of any page on our Website and following the instructions.

Your personal information will only be disclosed to third parties in the following circumstances:

where you would reasonably expect us to disclose it in order to provide the service in respect of which the information was originally collected;
where you have authorised us to do so;
where such disclosure is provided for under contract, including under this Privacy Policy or our Terms of Use;
where we are legally required to do so, for example, in response to a subpoena, court order or other legal process;
for compliance reasons to ensure compliance with relevant laws and regulations;
for operational reasons for maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our products or our computer systems in order to securely and efficiently deliver our services to you and others;
in exceptional circumstances, where there are grounds to believe that the disclosure is necessary to prevent a threat to an individual’s health and safety, for law enforcement purposes or to protect public health and safety; and
when it is otherwise required or authorised by law.

We will NEVER sell your personal information to anyone for direct marketing purposes or otherwise.

Cross-Border Disclosure of personal information

Wellthly is based in and operated out of Australia. Wellthly will, wherever possible, store your personal information on Australian servers.

Your rights in relation to your personal information

You may request access to your personal information collected by us and ask that we correct that personal information.

We may refuse to action your request where actioning the request would:

be unlawful;
prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security or negotiations with you;
jeopardise the conduct of existing or anticipated legal proceedings.

We may also refuse to action your request where we are authorised to do so by law.

How is your personal information protected, and how long is it kept?

Wellthly takes the security of your personal information very seriously and take reasonable steps to protect it from misuse and loss, unauthorised access, modification or disclosure. The methods we use to ensure this includes the implementation or existence of the following measures:

all Wellthly employees, agents and contractors are bound by confidentiality agreements and procedures have been implemented so that only those people with a genuine need to know have access to your personal information;
electronic and physical data and document storage security policies;
policies and procedures governing the retention, use and access of documents and data;
internal system access security policies including authenticated access of employees and contractors;
verification procedures to identify an individual before personal information is disclosed;
access control for our buildings and data hubs; and
the use of data encryption, firewalls and other security systems for our computer systems and cloud-based services.

Your information is kept while we need it to provide the services that you have requested from us and where applicable, we are required to keep it to comply with statutory requirements. Where Wellthly determines it is no longer necessary to hold your personal information we will securely destroy, delete or permanently de-identify that information, wherever possible.

In the unlikely event that the security of your personal information is compromised, we will immediately take steps to confirm if a data breach has occurred. If a breach is confirmed, and we form the view that the breach is likely to result in serious harm to you, we will notify you and provide you with a description of the breach, the kinds of information involved, and any recommended actions you could take to protect yourself against the consequences of the data breach. In accordance with our obligations under the Privacy Act 1988 (Cth) and the Australian Notifiable Data Breaches Scheme we will also notify the Office of the Australian Information Commissioner (OAIC) of any data breach that we consider is likely to result in serious harm to any of the individuals to whom the information relates.

Complaints about your privacy

Wellthly will make every attempt to ensure that your privacy is not breached, however, if you believe that your privacy has been breached or you wish to make a complaint about the way we have handled your personal information, you can contact us via the “Contact Us” button at the top of any page on our Website and following the instructions.

We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. However, if you believe that we have not resolved the issue you may refer the matter to the OAIC.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. We will let you know that the policy has changed by emailing you at the email address provided by you to us (if any) and also via a notification on our application. Your continued use of Wellthly or our services following notification of a change to this Privacy Policy indicates that you accept those changes. Through this document we will always let you know the information we collect, how we use it, and the circumstances under which such information may be disclosed by us.

Effective Date: 08 March 2024