Privacy Policy

Vivaci Industries Pty Ltd trading as Chiropractic Life (ABN 18 167 496 166) 

Privacy Policy

This is the privacy policy of Vivaci Industries Pty Ltd trading as Chiropractic Life (ABN 18 167 496 166) ( “we”, “us”, “our”, or “the Company” as the context may require). All customers, clients, and practice members of the Company are referred to in this policy as “you” or “your”. The purpose of this policy is to clearly state how the Company intends to meet its obligations under the Australian Privacy Principles (“APPs”) set out in the Privacy Act 1988 (Cth) (“Privacy Act”) in relation to personal data it collects from all its customers around the world. 

We recognise the importance of protecting your privacy and the security of your information and we want you to be as comfortable as possible when using the products and services we offer. If you do not agree with our Privacy Policy, you should not use our website, products or offerings. 

This Privacy Policy explains how we protect the privacy of the information that we collect across our business and the choices you have concerning the use of such information, among other important issues. Please read this Privacy Policy carefully as it will apply to the information we collect from you or about you.

We may amend this Privacy Policy from time to time. We will post any changes to this Privacy Policy here so that you will always know what the latest version of our Privacy Policy is. Please refer back to our Privacy Policy on a regular basis to ensure you are up to date. By providing us with information, using any of our Websites, our Products, or our Offerings, you agree to the terms of this Privacy Policy as updated.

Please remember that we are not responsible for the privacy of any information you reveal or post in any public forum (including but not limited to a message board, blog, or personal page) or for the privacy practices of websites that are operated or owned by third parties.

WHAT INFORMATION ABOUT YOU IS COLLECTED BY US?

We collect three (3) types of information: personally identifiable information, sensitive personally identifiable information and non-personally identifiable information.

Personally Identifiable Information (“PII”).

PII is information from which your identity is apparent or can reasonably be ascertained and includes personal information as defined under the Privacy Act. Such PII may include your name, address, email address, telephone number, and birth date. 

We may collect your credit card, banking details or billing and payment information in order to procure payment for our Offerings or Products you request, however such financial information will be treated in a different manner to the rest of your personal information, as detailed below. 

Unless you give us permission to do so, we will not sell, share, license, trade, or rent your PII other than as specified in this Privacy Policy. 

Sensitive Personally Identifiable Information (“Sensitive PII”). 

We may request Sensitive PII (which may include some health information and other sensitive information) from you and will collect Sensitive PII from you only if you voluntarily submit your consent for us to collect such information. For instance, we may collect information regarding your racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices, criminal record, health or genetic information or some aspects of your biometric information, with your consent.

Non-Personally Identifiable Information (“Non-PII“).

From time to time, we also may collect Non-PII that by itself cannot be used to identify or contact you, such as demographic information (like age, profession, or gender). Non-PII may also include user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of our Websites. Non-PII is used to help us understand who uses our Websites and to improve and market our Website and Online Products in particular and our Products and Offerings in general.

Information from Other Sources.

While we endeavour to only collect personal information from you directly, we may also supplement the information we collect with information from other sources that you may be unaware of to assist us in evaluating and improving our Products and Offerings, to determine your preferences so that we can tailor our Products and Offerings to your needs, and/or to study behavioural, health and wellbeing questions and trends in general. Such other sources include: 

– third parties (such as agencies on behalf of our commercial partners);
– public directories and listings;
– personal interactions with Company employees; and
electronic information from email or the Internet. 

WHAT ARE THE MAIN CONSEQUENCES IF YOU DO NOT PROVIDE PII?

You do not have to provide us with any PII or Sensitive-PII, however, if you choose to withhold requested information, we may not be able to provide you with our services, you may not be able to utilise our full offering, access special promotions or we may not be able to provide you with personalised support that is dependent upon the collection of such information.

WHERE AND WHEN IS YOUR INFORMATION COLLECTED BY US?

We may collect information (including Sensitive PII and PII) from you in a variety of different ways, both offline and online, through our online products or other means, for example:

– through your use of our products, offerings, features, tools, or resources that we provide on our Websites (collectively, our “Online Products”), and the Relationship Management Software needed to manage our services (the “Relationship Management Software”);
– when you attend an appointment at one of our Practices or when you join or participate in our program, including at a location where we deliver our program (our “Practices”), (the Online Products together with the Practices, our “Offerings”);
– by accessing, browsing or using any website owned and/or operated by us or on our behalf (each a “Website”);
– through purchase of our products, including in Practices or through a Website (collectively, our “Products”);
– when you participate in any promotions, surveys, or loyalty programs we run, sign up for our newsletters or otherwise make available to you; or
– through any other means. 

Becoming a Member. 

To access our Offerings, including Practices and certain Online Products, such as orthotics, pillows, and other aids, you must first complete certain steps. During these steps, you may be required to provide us with information (including PII) such as name, postcode, and email address, and, if you purchase our Products or subscribe to one of our Offerings, credit card, and payment information. This information is used to help us deliver our Products and Offerings to you, understand who uses our Website, Products, and Offerings, improve our offerings, for membership and billing purposes, and/or to contact you.

Practices.

We collect information, some of which may be Sensitive PII, that you voluntarily provide to us when you choose to attend a Practice. We collect this information in order to make our program available to you and to personalise your experience. 

Cookies and Action Tags on our Website.

We also collect Non-PII on our Website passively using “cookies” and “action tags”.

“Cookies” are small text files that are placed on your computer or mobile device in order to identify (i) your web browser, (ii) the activities of your computer on our Websites and (iii) your activity in connection with our advertisements and other marketing and promotional efforts. Cookies may be used to:
– personalise your experience on our Websites (e.g., to dynamically generate content on webpages specifically designed for you);
– assist you in using our Online Products (e.g., to save you time by not having to re-enter your name upon each visit to our Website); and
– allow us to statistically monitor how you are using our Websites for purposes of improving our online offerings.

We also may use cookies to conduct marketing and promotional efforts, tailor certain advertisements to your browser that we think may interest you, or determine the popularity of certain content. We may link the information stored in cookies to PII you provide us. To personalise your Website experience, we may store PII in an encrypted form in temporary or “session” cookies, which are erased when you close your browser.

In addition to cookies that we place on your computer, cookies may also be placed on your computer by third parties that we use to display or serve advertisements or to collect Non-PII in order to provide advertising-related services. For example, in the course of serving advertisements, our third-party ad servers may place or recognise a unique “cookie” on your browser. Neither these third parties nor their cookies collect PII on our Website, and we do not share PII with them without your permission or unless outlined under this Privacy Policy.

You do not have to accept cookies to use our Websites, however, you may not be able to use certain products, offerings, features, or resources of our Website (including our Online Products) if you do not accept cookies. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar.

“Action tags,” also known as web beacons or GIF tags, are web technology used to help track anonymous website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of our Websites, including advertisements, or emails sent on our behalf, may contain action tags. Unlike cookies, action tags are not placed on your computer.

We may select and use different third parties from time to time to track website usage through action tags on our Websites and on our advertisements on other websites. For example, these third parties may track anonymous website usage by setting a cookie (or reading a cookie previously placed by them) on users’ computers to track the activities of users who view a web page that contains action tags. These third parties may use information about your visits to this Website and other websites in order to provide advertisements about goods and services that may be of interest to you. Periodically, upon our request, these third parties may report the anonymous data that they collect on our behalf back to us for our internal use and analysis, and our treatment of this anonymous data is governed by the terms of this Privacy Policy.

By using cookies and action tags together, we are able to gain valuable information to improve our Website and our Online Products and measure the effectiveness of our advertising and marketing campaigns. We do not disclose any of your PII to our advertising partners through the use of cookies or action tags.

Finally, please note that advertisers and other third parties may also use their own cookies or action tags when you click on their advertisement or link to their website or service, on or from our Websites. This Privacy Policy does not govern the use by such third-party websites or providers of third-party advertising.

Social Media Features and Widgets on our Website.

Our Website includes social media features, buttons, and widgets provided by third-party social media platforms such as Facebook and X (collectively, the “Features”). A Feature may collect your IP address and which page you are visiting on our Websites, and may set a cookie to enable the Feature to function properly. This cookie may allow the social media platform to link the foregoing data with your user profile. The Features are either hosted by the third-party platform or directly on our Website. Your interactions with these Features are governed by the privacy policy of the relevant platform.

Online Products and Handheld Products.

We collect information, some of which may be PII, that you voluntarily provide to us when you choose to use some of our Online Products, such as the information that you provide voluntarily through responses to special Online Products such as surveys, questionnaires, self-assessment quizzes, contests and the like. Some of these Online Products may ask you for health-related information and it will be treated the same as any Sensitive PII (as defined above). 

Log Files of our Website.

We also collect Non-PII through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of our Websites. This information may be used to analyse trends, administer the Websites, monitor our Websites’ use, and gather general demographic information. We may link this information to PII for these and other purposes such as personalising your experience on our Websites and evaluating our Online Products in general.

Email or Refer a Friend.

Through our referral tools for informing a friend about our Websites, or one of our Products or Offerings, we will allow you to send your friend a one-time email containing the information you request to be sent. If you elect to use these referral tools, we will collect from you certain PII about you that you have provided, but your friend’s data, such as your friend’s name and email address, will only be used for the purposes of sending the message.

WHAT DO WE DO WITH THE INFORMATION WE COLLECT AND WHERE DO WE HOLD IT?

In general, we use the PII and Non-PII collected to provide you with the relevant Products and Offerings (which on digital platforms may include the display of personalised content and advertising), to fulfil administrative functions associated with these services, for example, billing and account management, to enter into contracts with you, to personalise your experience and for member relationship purposes. 

We will only use Sensitive PII, including health-related information, we hold about you for the primary purpose for which it was collected or for a purpose directly related to the primary purpose, and where you would reasonably expect us to use or disclose it for that purpose.

From time to time, we will also use PII (but not Sensitive PII) for the purpose of marketing to you, including, through electronic channels. This will include letting you know about new products and services we or any of our specially-selected partners offer, promotions, and other opportunities in which you may be interested. You can contact us at any time if you wish to change your preferences for marketing purposes (see Contacting Us below for more information). 

We may also use PII (but not Sensitive PII) collected to contact you about important service announcements and updates regarding our Website, Products, or Offerings, including information about your billing account status. You will not be able to “opt-out” of these service announcements and updates as they contain important information relevant to your use of our Website, Products, and Offerings and are not promotional in nature. If you do not wish to receive these service announcements, you may cancel your account with us and inform us that you no longer wish to receive any communication from us, including service announcements by contacting our Privacy Coordinator at the address set out below. 

We may also use your PII (but not Sensitive PII) for other related business purposes, such as to cross-reference it with data collected and stored by our commercial partners on their databases, to see if we, together with our partners, can better tailor and improve our products and services. We may also seek to contact you on social media using the PII we have on record, for instance, to invite you to follow us on social media platforms like Facebook and X.

We may also use the Non-PII gathered on our Websites and through our Products and Offerings to perform statistical analysis of user behaviour, to analyse and evaluate issues relating to behaviour, health and well-being, or to evaluate and improve our Products and Offerings. 

When you provide us with your PII, this information may be collected, stored, and processed on secure servers located in Australia or New Zealand or outside of Australia and New Zealand.

WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?

Where your PII is disclosed, we will seek to ensure that the transfer of your personal information is carried out in accordance with applicable privacy and data protection laws and codes. 

If your Sensitive PII is required to be disclosed, we will seek to ensure this is at all times only when required under the primary purpose and is carried out in accordance with applicable privacy and data protection laws and the relevant Australian Health Practitioner Regulation Agency and Chiropractic Board of Australia codes and guidelines.

Laws and Legal Rights.

We may also disclose your information (including PII) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose PII in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Website Terms & Conditions or our Membership Agreement, or to protect the safety and/or security of our customers, users, our Websites or the general public.

Third Parties Generally.

We may provide to third parties Non-PII about you that does not allow you to be identified or contacted, including where such information is combined with similar information of other users of our Website, Products or Offerings. For example, we might inform third parties regarding the number of unique users who visit our Websites, the demographic breakdown of the community users of our Websites, or the activities that visitors to our Websites engage in while on our Websites. The third parties to which we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers, and other similar parties. Third parties will not receive Sensitive PII, unless required under the primary purpose.

Outside Contractors.

We may provide to independent contractors, vendors, and suppliers (collectively, “Outside Contractors”) information about you to provide specific services and products related to our Website, Products, and Offerings, or to help us provide, improve and market our goods and services. These Outside Contractors may sometimes have limited access to your information, including PII, in the course of providing products or services to us. Access to your PII by these contractors is limited to the information reasonably necessary in order for the Outside Contractors to perform their limited function for us. We also require that these Outside Contractors (i) protect the privacy of your PII consistent with this Privacy Policy, and (ii) not use or disclose your PII for any purpose other than providing us with products or services for which we contracted. Outside Contractors will not receive Sensitive PII, unless required under the primary purpose.

Third-Party Sellers.

In addition, through our Websites, you may be given the opportunity to purchase (or to obtain more information regarding) certain content, products, or services which are sold through a person or company other than us or our Affiliates (collectively, “Third Party Sellers“). We will attempt to make it clear to you when you are dealing with a Third-Party Seller by opening a new browser or otherwise notifying you that you are leaving our Websites. For example, if you see a phrase such as “powered by” or “brought to you by” followed by the name of a person or company other than Vivaci Industries Pty Ltd, then you are likely on, or about to enter, a website hosted or operated by a person or company other than us. Third-Party Sellers may request that you submit certain information to them in order to purchase their products or services or to obtain additional information from them. You do not need to submit this information or purchase any products or services from Third Party Sellers to access our Websites. By submitting the requested information, you affirmatively consent to have that information collected by the Third-Party Seller. This information is used by the Third-Party Seller and may be subject to a different privacy policy and will have their own obligations regarding treatment of your information, and if you have any concerns about the Third Party Sellers you should liaise with them directly. We do not otherwise share or disclose your PII to Third Party Sellers other than as detailed under this Privacy Policy.

Sale of Business.

We reserve the right to transfer information (including your PII and Sensitive PII) to a third party in the event of a sale, merger, or other transfer of all or substantially all of the assets of any of us or our Affiliates provided that the third party agrees to adhere to the terms of this Privacy Policy. We will notify users of any such transfer through notice on our Websites and through email.

DOES THIS PRIVACY POLICY APPLY WHEN YOU LINK TO OTHER WEBSITES?

Our Websites contains links to other websites not owned or operated by us. We will attempt to make it obvious to you when you leave our Websites and enter these websites by opening a new browser or otherwise notifying you that you are leaving our Website. However, please be aware that we are not responsible for the privacy practices of such websites. We encourage you to be aware when our Websites links to other websites and to read the privacy policies or statements of each and every website. This Privacy Policy applies solely to our collection, storage and use of PII collected via the Websites or otherwise in the course of our business, and does not apply to any third party.

IS THE INFORMATION WE COLLECT SECURE?

We want your information (including PII and Sensitive PII) to remain as secure as reasonably possible. We strive to provide secure transmission of your information from your computer to our servers through industry-standard techniques. To help ensure the integrity and privacy of the PII you provide to us via the Internet at the time you elect to become a community user or subscribe to our Online Products, we use Secured Socket Layer (SSL) encryption technology in transmitting such PII and Sensitive PII over the Internet to our servers. We also take reasonable and practicable measures to secure the data provided to us in Practice and otherwise in an offline context. Regarding all information, we take steps as are reasonable in the circumstances to protect the information from misuse, interference and loss and from any unauthorised access, modification, or disclosure.

The servers on which we store PII and Sensitive PII are located in controlled, secure environments, protected from unauthorised access, use, or alteration. We recognise the trust you place in our company through your dealings with us across our various platforms, and we do everything we can to maintain that trust, and we will only use your personal information in a manner consistent with this Privacy Policy.  

With respect to transmission by the Internet, notwithstanding the above commitments to protect your information (including PII and Sensitive PII) from loss, misuse, or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot absolutely ensure or warrant the security and privacy of any information you transmit to us, and you do so at your own risk.

WHAT CHOICES DO YOU HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF YOUR INFORMATION?

Except as otherwise described in this Privacy Policy, we will only use PII for the purposes described above or as otherwise disclosed at the time we request such information from you. We will only use Sensitive PII we hold about you for the primary purpose for which it was collected or for a purpose directly related to the primary purpose

You must “opt-in” and give us permission to use your PII for any other purpose. If you no longer wish to receive marketing communications from us via postal mail, you may notify us by calling us at +61 08 7981 5895 or by contacting our Privacy Coordinator at the address set out below. You may change your preference and “opt-out” of receiving online/electronic marketing communications by following the directions provided in association with the communication, or by contacting our Privacy Coordinator at the address set out below.

Generally, users of our Websites are notified when PII is being collected by third parties on our Website. We do this so you can make an informed choice as to whether you should disclose information to a third party.

CAN YOU ACCESS, UPDATE, OR CORRECT YOUR INFORMATION?

You can always contact us in order to (1) access your PII or Sensitive PII, (2) update or correct your PII or Sensitive PII, (3) change your preferences with respect to communications and other information you receive from us, or (4) delete the PII (but not Sensitive PII) maintained about you on our systems, by accessing Account Settings or contacting our Privacy Coordinator at the address set out below. Such updates, corrections, changes, and deletions will not have an effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change, or deletion. However, if you so request, we will take such steps as are reasonable in the circumstances to notify any other entity with whom we have shared your PII of any such correction that has taken place unless it is impracticable or unlawful to do so. 

Sensitive PII may be deleted upon your request, unless we are required to retain your Sensitive PII on our systems in accordance with the relevant laws and regulations.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our systems. The need to back up our systems to protect information from inadvertent loss means that a copy of your PII or Sensitive PII may exist in a non-erasable form that will be difficult or impossible for us to locate. We promise that promptly after receiving your request, all PII stored in databases we actively use and other readily searchable media will be updated, corrected, changed, or deleted, as appropriate, as soon as reasonably practicable.

DO WE DISCLOSE PII OR SENSITIVE PII TO OVERSEAS RECIPIENTS?

We may disclose information (including PII) about you to our Affiliates within Australia, New Zealand, the United States, the United Kingdom, or elsewhere overseas, and potentially to other overseas entities.

At any time that your PII is transferred to overseas recipients, we shall take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the applicable sections of the APPs in relation to the information. If you are concerned or have any issues regarding overseas disclosure, please contact us.

“Affiliates” means any person or entity which directly or indirectly controls, is controlled by, or is under common control with Vivaci Industries Pty Ltd, whether by ownership or otherwise. Any information relating to you that we provide to our Affiliates will be treated by those Affiliates in accordance with the terms of this Privacy Policy. We may share your information (including PII) with franchisees of Vivaci Industries Pty Ltd, but only where we indicate to you at time of information collection that such information may be provided to a franchisee, or if we otherwise obtain your consent.

WHOM DO YOU CONTACT IF YOU HAVE ANY PRIVACY QUESTIONS OR WISH TO MAKE A COMPLAINT?

If you have any questions about our Privacy Policy or feel that we are not abiding by the terms of our posted Privacy Policy, or otherwise if you wish to make a complaint, please contact us in either of the following ways, leaving us your reply contact details:

Email us at: policy@chiropracticlife.com.au

Or, write to us at:
Chiropractic Life
46 Vanderlin Drive,
Wagaman NT, AUSTRALIA 0810

Attn: Privacy Co-ordinator

Any complaints you make with us will be dealt with as soon as is practicable during business hours. You will generally be contacted regarding your correspondence through the contact details provided.

BY USING OUR WEBSITE, ONLINE PRODUCTS, PRODUCTS, OR OFFERINGS, OR OTHERWISE, PROVIDING INFORMATION TO US AS SET FORTH IN THIS PRIVACY POLICY, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE OUR WEBSITE, ONLINE PRODUCTS, PRODUCTS, OR OFFERINGS. YOUR CONTINUED USE OF OUR WEBSITE, ONLINE PRODUCTS, PRODUCTS, OR OFFERINGS FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY WILL MEAN THAT YOU ACCEPT THOSE CHANGES.

 

Last updated 16th September 2024