Privacy Policy

This Privacy Policy applies to all personal information collected by Pinnacles Health Technologies Pty Ltd (we, us or our) via the website located at www.pinnacleshealth.com (Website).

WHAT INFORMATION DO WE COLLECT?

The kind of Personal Information that we collect from you will depend on how you use the Website. The Personal Information which we collect and hold about you may include:

• name, email address, and any details submitted via our contact form (including the category and content of the message); and
• technical and usage information such as IP address, browser type, device information, and browsing behaviour on our Website through Google Analytics.

We do not collect health, biometric, or fitness data through this Website. Such data is only collected via the separate Pinnacles Gym application, which is governed by a separate privacy policy.

TYPES OF INFORMATION

The Privacy Act 1988 (Cth) (Privacy Act) defines types of information, including Personal Information and Sensitive Information.

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.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as Personal Information and will not be subject to this Privacy Policy.

Sensitive Information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive Information will be used by us only:

• for the primary purpose for which it was obtained;
• for a secondary purpose that is directly related to the primary purpose; and
• with your consent or where required or authorised by law.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect Personal Information when you submit it through the Website, including through the contact form, when you communicate with us by email or other correspondence following a Website enquiry, or when you otherwise provide it directly to us.

This Privacy Policy applies to Personal Information collected through or in connection with the Website. The Pinnacles Gym application is governed by a separate privacy policy.

We may collect cookies and usage analytics from your computer, including through Google Analytics, which enable us to tell when you use the Website, customise your Website experience, and understand how users interact with our Website. This may include technical information such as IP address, browser type, device information, and browsing behaviour. As a general rule, it is not possible to identify you personally from our use of cookies. By continuing to use the Website, you consent to this tracking. You may manage your cookie preferences and opt out of Google Analytics tracking through our Cookie Policy or your browser settings. For details on how Google processes this data, please review Google's Privacy Policy.

Personal Information submitted through the Website contact form is stored in Firebase Storage configured in Australia.

We use Firebase Cloud Functions and related Google services to operate the contact form, process submissions and send enquiry details to admin@pinnacleshealthtech.com. These services may process Personal Information in Australia and, in some circumstances, outside Australia, including in the United States.

Before using service providers that may handle Personal Information outside Australia, we take reasonable steps to ensure that those providers handle the information in a manner consistent with applicable Australian privacy obligations. Where we disclose Personal Information to an overseas recipient, we remain accountable for how that recipient handles the information.

For further information about how Google handles Personal Information, please refer to Google's Privacy Policy and Firebase privacy information.

We do not request or require sensitive information, including health information, through the contact form. If you choose to include sensitive information in a contact form submission, you consent to Pinnacles Health Technologies Pty Ltd collecting, storing and using that information to receive, assess and respond to your enquiry.

Any sensitive information submitted through the contact form is stored in Firebase Storage and sent to admin@pinnacleshealthtech.com for follow-up correspondence. Access to that information is limited to those responsible for managing enquiries.

Sensitive information submitted through the contact form will only be used for the primary purpose for which it was provided, for a secondary purpose directly related to that primary purpose, or where required or authorised by law.

Where communication is requested by you or is indicated by us from our interpretation of the data within the contact form, we will use information from the contact form to contact you specifically regarding what was provided via the contact form.

Where reasonable and practicable we collect your Personal Information from you only. However, sometimes we may be given information from a third party, in which case we will take steps to make you aware of the information that was provided by a third party.

PURPOSE OF COLLECTION

We collect Personal Information to provide you with the best service experience possible on the Website and keep in touch with you about developments in our business.

We only disclose Personal Information, including any sensitive information voluntarily submitted through the contact form, to service providers who assist us in operating the Website and managing enquiries. Your Personal Information may also be accessible from time to time to maintenance and support personnel acting in the normal course of their duties.

Where we engage service providers to handle Personal Information on our behalf, we take reasonable steps to ensure those providers implement appropriate technical and organisational security measures and handle Personal Information in a manner consistent with applicable Australian privacy obligations. For large platform providers whose standard terms govern the arrangement, we rely on those terms together with any applicable data processing commitments published by the provider.

If we become aware of a suspected data breach involving Personal Information, we will take reasonable steps to contain the incident and assess whether the breach is likely to result in serious harm to any affected individual.

Where required under the Notifiable Data Breaches scheme in the Privacy Act 1988 (Cth), we will notify the Office of the Australian Information Commissioner and affected individuals as soon as practicable after forming the view that an eligible data breach has occurred.

Any notification will include the information required by law, including a description of the data breach, the kinds of Personal Information concerned and recommendations about steps affected individuals should take in response.

We will not use sensitive information, including any health or health-adjacent information voluntarily submitted through the contact form, for direct marketing purposes without your explicit consent. This is consistent with our obligations under Australian Privacy Principle 7, which prohibits the use of sensitive information for direct marketing without explicit consent.

SECURITY, ACCESS AND CORRECTION

We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure. Personal Information submitted via our contact form is processed and stored using Google Firebase Storage and Firebase Cloud Functions, both of which apply Google's encryption and security standards. Usage analytics collected through Google Analytics are subject to Google's own security measures. Our Website operates over HTTPS and we implement appropriate technical and organisational safeguards to protect Personal Information collected through the Website. When we no longer require your Personal Information for the purpose for which it was obtained, we will take reasonable steps to destroy, anonymise or de-identify it. Most of the Personal Information stored in our records will be kept for a maximum of 7 years to fulfil our record keeping obligations.

The Australian Privacy Principles:

• permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and
• allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).

Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this Privacy Policy.

Contact form submissions and general enquiries are retained for a maximum of 7 years unless they relate to a service request or complaint, in which case they are retained for 7 years. All Personal Information is securely deleted or de-identified upon expiration of the applicable retention period, except where retention is required by law.

COMPLAINT PROCEDURE

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us as on the contact details set out at the bottom of this policy. All complaints will be considered by the relevant staff of Pinnacles Health Technologies Pty Ltd and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

HOW TO CONTACT US ABOUT PRIVACY

If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact us through: admin@pinnacleshealthtech.com.