Effective Date: March 13, 2019
Policy Version: 2.0
Genescript Pty Ltd ATF The Genescript Trust (ABN 41 746 837 996) trading as Breakfree Nutrition, herein referred to as "us", "we" or "our", is committed to protecting your privacy and personal information.
Privacy Officer Contact Information
Breakfree Nutrition Privacy Officer
Level 5 Holman Hodge
420 King William Street
Telephone: 1300 39 40 50 (Australia wide)
Email: Please use our Contact Us Form
‘NONPERSONAL DATA’ (NPD) is information that is in no way personally identifiable.
‘PERSONAL DATA’ (PD) means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.
Table of Contents
- Information We Collect and How We Collect It
- How Your Information Is Used and Shared
- Retaining and Destroying Your PD
- Updating Your PD
- Revoking Your Consent for Using Your PD
- Protecting the Privacy Rights of Third Parties
- Links to Other Websites
- Protecting Children’s Privacy
- Our Email Policy
- Our Security Policy
- Use of Your Credit Card
Information We Collect and How We Collect It
Generally, you control the amount and type of information that you provide to us when using our website.
Our Basis for Collecting and Processing PD
Our basis for collecting and processing your PD when you buy our products or services is based on and the necessity for the performance of a contract or to take steps to enter into a contract.
Our basis for collecting and processing your PD when you sign up for our free trainings, download free information, access free audios, videos, and webinars or schedule a free Breakthrough Session through our website, including information you enter using any of our opt-in forms is based on consent. You consent by providing this information to us and ticking a check-box on the registration form; or by acknowledging the double opt-in confirmation email we send you.
Our basis for collecting and processing your PD may also be for the purposes of managing and responding to your inquiries; understanding and meeting your usage needs for our products and services; identifying the products and services that are most valued and to identify gaps or shortfalls in our product and services offerings so we can develop new products and services and enhance existing ones; to detect, monitor, investigate, mitigate, or attempt to prevent fraud and technical or security issues or to protect our products, services and property; and manage our recruitment process and other critical business operations.
We Collect Your PD in the Following Ways:
We automatically receive information from your web browser or mobile device. This information may include the name of the website from which you entered our website, if any, as well as the name of the website you’ll visit when you leave our website. This information may also include the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our website. We use all this information to analyze trends among our users to help improve our website.
When Entering and Using Our Website
When you enter and use our website some of these cookies may contain your PD.
Performance Cookies - These cookies collect information about the use of the website, such as pages visited, traffic sources, users’ interests, content management, and other website measurements.
Functional Cookies - These cookies enable the website to remember users’ choices, such as their language, usernames, and other choices while using the website. They can also be used to deliver services, such as letting a user listen to audios, or watch videos on the website.
Media Cookies - These cookies can be used to improve a website’s performance and provide special features and content. They can be placed by us or third parties who provide services to us.
Advertising or Targeting Cookies - These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.
Session Cookies - These cookies allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse a website. Session cookies also permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; they are not stored long term.
Persistent Cookies - These cookies are stored on a user’s device between browser sessions, which allows the user’s preferences or actions across a website or across different websites to be remembered. Persistent cookies may be used for several purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.
- identifying the areas of our website that you have visited
- personalizing content that you see on our website
- our website analytics
- remarketing our products or services to you
- remembering your preferences, settings, and login details
- targeted advertising and serving ads relevant to your interests
- allowing you to post comments
- allowing you to share content with social networks.
We may also use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers and users.
When Registering for a Free Service
When you sign up to receive a free training, webinar or download (e.g. PDF file), we collect your first name and email address.
When Booking a Free Breakthrough Session
When you book a Breakthrough Session via our online scheduler we collect your full name, email address, mobile phone number and Skype user name if you choose to connect via Skype.
You will also be required to complete an online survey that collects your age, weight, and other information about your eating challenges. For maximum privacy and security, this survey does not collect any personally identifiable information such as your name, email or contact phone number.
When Buying Products or Services
If you buy products or services from us, we collect your first and last name, email address, physical address, phone number and credit card or other payment information.
You will also be required to complete an online survey that collects more detailed information about your physical and psychological health, lifestyle choices, eating habits, goals and challenges. For maximum privacy and security, this survey does not collect any personally identifiable information such as your name, email or contact phone number.
Collecting Information About Your Physical Location
When you use our services, we may collect and process information about your actual physical location. We use geo-locating technologies and IP tracking to determine your location.
Website Chat Software or Contact Forms
Our website contains chat software or contact forms that enable visitors to communicate with us live online or offline by email. In some cases visitors can communicate with us without buying our products and services. When you use our chat software or contact forms, we may collect some or all the following information: your email address, name, contact phone number, location, and any other information you willingly choose to give us. You should limit the information you give to us to one that is necessary to answer your questions.
Google Ad and Content Network
Our website uses Google Analytics to collect information about the use of our website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our website, what pages they visit, and what other websites they have used before coming to our website. We use the information we get from Google Analytics to analyze traffic, improve our marketing, advertising, and website. Google Analytics collects only the IP address assigned to you on the date you visit our website, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our website.
For more information on how Google collects and processes your data visit: https://www.google.com/policies/privacy/partners/
You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout
Our website uses analytics and crash reporting services from several companies to collect information about the use of our website. Analytics collects information such as how often users visit our website, what pages they visit, when they do so, what other websites they used before coming to our website, and their IP addresses. We use the information we get from analytics to improve our services.
Third parties, including Facebook, may use first-party cookies, third-party cookies, web beacons, and other storage technologies to collect or receive information from our services and elsewhere on the Internet, and use that information to provide measurement services and target ads. With Facebook remarketing you may see our ads on Facebook after you have used our services. For this to happen Facebook uses unique cookies that are activated and placed in a visitor’s browser when they land on a webpage. Facebook lookalike audience targeting allows us to show ads on Facebook to people who are similar to those who have already visited or made a purchase from our services. To opt out of Facebook’s collection and use of information for ad targeting visit: https://www.facebook.com/help/568137493302217
What Happens If You Don’t Give Us Your PD
If you do not provide us with enough PD, we may not be able to provide you all our products and services. However, you can access and use some parts of our website without giving us your PD.
How Your Information is Used and Shared
We use the information we receive from you to:
- provide our products and services you have requested or purchased from us
- personalize and customize our content
- make improvements to our website
- contact you with updates to our website, products, and services
- resolve problems and disputes
- contact you with marketing and advertising that we believe may be of interest to you.
Communications and Emails
When we communicate with you about our website, we will use the email address you provided when you registered as a user or customer. We may also send you emails with promotional information about our website or offers from us unless you have opted out of receiving such information. You can unsubscribe from our emails anytime by clicking the “Unsubscribe” link located at the bottom of our emails. You can also change your contact preferences by contacting us using the contact information at the top of this privacy notice.
Sharing Information with Affiliates, Business Partners and Other Third Parties
We do not sell or rent your PD to third parties for marketing purposes. We may give your PD to third-party service providers whom we hire to provide services to us. These third-party service providers may include but are not limited to payment processors, web analytics companies, advertising networks, data and website management services, task/goal/habit tracking and management applications, help desk providers, appointment scheduling services, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.
PD that we collect from you may be stored, processed, and transferred outside of Australia in/to countries in which our service providers operate. Wherever we transfer, process, or store your PD, we will take reasonable steps to protect it. By using our website, services, or products you agree to the transfers of your PD.
Sharing Your PD for Lookalike or Similar Audience Marketing
We may share your PD with third parties for similar audience marketing purposes. Similar audience marketing is also called lookalike audience marketing. The third parties we share your PD with for this type of marketing include Facebook and/or Google. Using your PD for similar audience marketing or lookalike audience marketing helps us find new audiences (users and customers) based on similar interests to yours. This helps us improve our marketing services. Your PD is only shared with Facebook and Google for this type of marketing. By using our website and agreeing to our privacy notice you are giving consent for your PD to be used for the marketing purposes described within this section.
Text Messaging and Push Notifications
If you provide a mobile telephone number to us, you are giving your consent and authorize us or a third party to send you text messages and push notifications. You are not required to give us your consent for these text messages and push notifications. However, withholding your consent may interfere or prevent us from providing some or all of our services to you. You can stop receiving text messages and push notifications at any time by contacting us.
Legally Required Releases of Information
We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or governmental enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms and conditions; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.
Disclosures to Successors
If our business is sold or merges in whole or in part with another business that would become responsible for providing the website to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.
Community Discussion Boards, Blogs, or Other Mechanisms
Our website may offer the ability for users to communicate through online community discussion boards, blogs, or other mechanisms. We do not filter or monitor what is posted on such discussion mechanisms. If you choose to post on these discussion mechanisms, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you disclose your PD through such postings. Also, PD which you post on our website for publication may be available worldwide by means of the Internet. We cannot prevent the use or misuse of such information by others.
Retaining and Destroying Your PD
We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic, paper, or a combination of both forms. When your information is no longer needed, we will destroy, delete, or erase it.
Updating Your PD
Revoking Your Consent for Using Your PD
You have the right to revoke your consent for us to use your PD at any time. Such opt-out will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept. If you want to revoke your consent for us to use your PD, please contact us through the contact information at the top of this privacy notice.
Protecting the Privacy Rights of Third Parties
If any postings you make on our website contain information about third parties, you agree to make sure that you have permission to include that information. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others.
Links to Other Websites
Our website may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. These websites will likely have their own privacy notices. We have no responsibility for these websites and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your PD.
Protecting Children’s Privacy
Even though our website is not designed for use by anyone under the age of 18, we realize that a child under the age of 18 may attempt to access our website. We do not knowingly collect PD from children under the age of 18. If you are a parent or guardian and believe that your child is using our website, please contact us. Before we remove any information we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child is accessing our website, we will delete his/her information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor have any liability to do so.
Our Email Policy
We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.
You can always unsubscribe from receiving our emails by simply clicking the “unsubscribe” link provided at the bottom of every email from us.
Our Security Policy
We take all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
- premises security;
- restricted file access to personal information;
- deploying technological safeguards such as security software and server firewalls to prevent hacking or unauthorized computer access;
- internal password and security policies; and
- secure socket layer technology (SSL).
We have built our website using industry-standard security measures and authentication tools to protect the security of your PD. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your PD. Unfortunately we cannot guarantee prevention of loss or misuse of your PD or secure data transmission over the Internet because of its nature. We strongly urge you to protect any password you may have for our website and not share it with anyone.
Use of Your Credit Card
You may have to provide a credit card to buy products and services from our website. We use third-party billing services and have no control over them. We use commercially reasonable efforts to ensure that your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.
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