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BETTY BAXTER PRIVACY POLICY

This Privacy Policy forms part of the Terms of Use of the Betty Baxter website www.bettybaxter.com.au and supports the delivery of the Betty Baxter Complete Weight Management program in participating pharmacies.

BY USING THE BETTY BAXTER WEBSITE YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU SHOULD NOT USE THIS WEBSITE.

This Privacy Policy may be amended and updated from time to time. All updates will be posted on this website and the posted policy remains current at all times.

YOUR CONTINUED USE OF THIS WEBSITE FOLLOWING THESE UPDATES AND THE POSTING OF ANY CHANGES TO THIS POLICY WILL BE TAKEN AS YOUR ACCEPTANCE OF THESE CHANGES AND OF THE UPDATED POLICY.

Betty Baxter Pty Ltd (ABN 96 725 359 452) “Betty Baxter” respects and values your privacy, and recognises that your privacy and the security of your personal information needs to be maintained.

Betty Baxter makes every effort to comply with the requirements of the Privacy Act 1988 (C’lth) and has developed this Privacy Policy to outline our practices and procedures regarding the collection, storage and use of your personal information. This Privacy Policy is also intended to advise you of our obligations and your rights relating to your personal information and is intended to comply with the ten National Privacy Principles prescribed by the Act. A copy of the Act is available at Privacy Act 1988 (Cth).

What information is collected?

Betty Baxter collects and holds your personal information only as it applies to providing you with products, services and updated information regarding our products and services. Personal information includes your name, address, street address, postal address, email addresses, phone numbers, membership number, payment details, account number and records of correspondence and billing.

Unencrypted credit card details will not be saved on our internet servers.

Betty Baxter may collect sensitive personal information from you, but this will only be collected with your consent and in relation to your participation in our weight management program. This information may include family medical history, dietary requirements, previous or current illnesses and injuries, and information about your past and current state of health including height, weight and age.

The Betty Baxter program has not been specifically designed for people under 18 years of age and does not allow persons under the age of 18 years to purchase products online. Betty Baxter will therefore not knowingly collect, use or disclose personal information about a child or person under 18 years of age. Persons under 18 years of age are only able to participate on the program with doctor’s advice, parent’s consent and under the supervision of a pharmacy based trained Betty Baxter consultant.

How information is collected.

Betty Baxter collects personal information in several ways:

1. In pharmacy – directly through our personal weight loss consultants

2. Online – directly through registration forms, purchase information, forum registration, emails, and feedback from our member forum

3. Other – directly through other correspondence such as telephone conversations, written communications, other parties, other websites, journals, phone books

Betty Baxter may hold your personal information in hard copy and electronic forms. All written correspondence is held in hard copy and may be scanned and stored in electronic form. Registration and personal progress forms may be held in hard copy and electronic forms. Betty Baxter’s client database and email correspondence are held in electronic forms.

How does Betty Baxter use Personal Information?

Betty Baxter uses personal information to enable Betty Baxter to support you while you are on the Betty Baxter Complete Weight Management Program and to provide you with information on products and services.

Betty Baxter may need to disclose some of your personal information such as your address to a delivery service so that we can arrange for the products you order to be delivered.

Betty Baxter may provide your contact details (phone numbers and/or email addresses) to pharmacies where you have given your consent and have requested to be contacted by a pharmacy based Betty Baxter consultant.

Betty Baxter may use data recorded and provided to your pharmacy and/or to Betty Baxter that is associated with your weight loss in it’s marketing on an anonymous basis. Betty Baxter will not identify you in any marketing unless prior written consent has been received from you.

We may also ask for your consent to provide your personal information to third parties to send you marketing information that you have indicated may be of interest of you. If you consent and provide such information, we will only use the information for the purposes to which you have consented.

Betty Baxter may retain your order details in hard copy and/or in a secure database to ensure we have a record of your order should you have any queries relating to the delivery of your order.

How does Betty Baxter disclose your information?

Betty Baxter will only disclose your personal information for a purpose related to providing you with products and services related to the Betty Baxter Complete Weight Management Program. Betty Baxter will not disclose personal information about you or access correspondence about you on the web without your consent unless it is considered necessary to:

1. comply with the law, or

2. protect the rights and/or property of Betty Baxter, Betty Baxter Clients or any other person, or

3. minimise or prevent any threat to the health, safety and/or well-being of any person

Betty Baxter may share aggregated geographic and/or demographic personal information provided to Betty Baxter with its business partners, service providers and advertisers. This information will not contain details that could be used to identify any individual unless prior written approval is gained from you.

Under no circumstances will Betty Baxter sell or receive payment for licensing or disclosing your personal information.

Cookies

A cookie is a small file containing data that is stored on a user’s computer hard drive. The cookie stores a small amount of information about the user and about our website.

A cookie also stores some of the data provided during online registration and allows the Betty Baxter server to keep a record and information about traffic on our website. This information assists us in evaluating use of our website and helps us with future improvements to our website.

Cookies make our website easier to use. If you have your system set to reject cookies, you can still use our website, but you may not be able to take advantage of certain features. You can delete cookies from our hard drive, however, if you choose to do so you should first seek advice from your systems administrator or internet provider.

Credit card information is never stored in a cookie.

Independent contractors

Betty Baxter engages independent contractors to provide specific services related to the Betty Baxter Complete Weight Management Program. These services may relate to the ongoing development and/or maintenance of computers, email services, this website and the provision of credit card processing and fraud screening and prevention.

These independent contractors may be provided with limited access to information, including access to your personal information where such access is reasonably necessary for them to perform their role. Where such access is granted, Betty Baxter required independent contractors to comply with this Privacy Policy and with the standards set out in the Privacy Act 1988 (Cth), and to not use or disclose any personal information for any purpose other than to provide the service for which they are contracted.

Sale of business

Betty Baxter reserves the right to transfer information, including your personal information, to a third party such as any entity affiliated with Betty Baxter in the event of a sale, merger or other transfer of all or of substantially all of the assets of Betty Baxter, provided that any third party agrees to adhere to the terms of this Privacy Policy.

How secure is the personal information held by Betty Baxter?

Betty Baxter holds all personal information in a secure manner and adopts strict procedures to ensure that the information is protected from misuse, unauthorised access, modification and disclosure. Only staff that require access to your personal information have access to relevant records. Records are deleted once they are no longer needed or required to be kept by law. Once the information is no longer required, hard copy records are shredded and electronic records are deleted.

Betty Baxter endeavours to provide a secure environment for transmission of information from your computer to our server, and vice versa, and strives to adopt practices that are recognised as industry best practice. Betty Baxter uses firewalls and Secure Socket Layer “SSL” encryption technology to ensure the integrity and privacy of any personal information held. Unencrypted credit card details are not stored on our server, and only encrypted information relating to your credit card details is transmitted when you use our website. In addition, Betty Baxter’s order processing system is protected by a secure firewall which restricts access to authorised users only.

When online, your personal information is protected and is only accessible to those who can supply your username and password. However, information posted by you in a discussion forum can be collected and used by others without your consent of knowledge. We therefore recommend you take care and maintain the security of your username and password, account information and other personal information and/or confidential information when online.

Access to your personal information

You can request access to your personal information held by Betty Baxter at any time by sending a written request to the Privacy Officer in any of the following ways:

By Email:

info@bettybaxter.com.au

By Mail:

Privacy Officer

Betty Baxter Pty Ltd

PO Box 2129

Fortitude Valley BC QLD 4006

By Fax:

+61 7 3251 3570

Betty Baxter may charge you a reasonable fee for providing access to your information and presenting it in a reasonable form. If a fee is required, the Privacy Officer will notify you of the basis for charging the fee, prior to providing the information.

In exceptional or rare circumstances, Betty Baxter may not be able to provide you with access to your personal information. These circumstances are set out in the Privacy Act 1988 (Cth). If Betty Baxter is unable to provide you with access to the information requested, the Privacy Officer will advise you why the request for information cannot be granted.

Correcting of changing your personal information

In the event that the personal information held by Betty Baxter is incorrect of out of date and cannot be updated online by you, it is your responsibility to notify the Privacy Officer of the need to change the information, and to provide with the correct information. Betty Baxter will update the information for you. To have your information updated, use the contact details provided in the “Access to your personal information” section of this Privacy Policy.

Promotional and Marketing Information

To assist and support you while you are using the Betty Baxter Complete Weight Management Program range of products and services, Betty Baxter may send you hard copy marketing information, including newsletters, special offers and other information about products and services that may help you reach your goal weight. If you do not wish to receive any of this additional information, please contact our Privacy Officer and we will ensure that your details are removed from our mailing list.

Betty Baxter may also invite you to subscribe to newsletters and promotional materials that are distributed to you in electronic format. If you wish to unsubscribe to these materials at any time, simply follow the online instructions, contact us via the “Contact Us” page on our website to request you be unsubscribed from these materials, or contact our Privacy Officer to ensure your details are removed from these electronic mailing lists.

Complaints about the handling of personal information

Betty Baxter is committed to upholding the ten National Privacy Principles set out in the Privacy Act 1988 (Cth) and strives to maintain privacy and security of your personal information.

If you are not satisfied with the way Betty Baxter had handled your personal information, you are entitled to lodge a complaint with the Federal Privacy Commissioner. Information about how you can lodge a complaint can be found on the Privacy Commissioner’s website (www.privacy.gov.au) or by calling the Privacy Commissioner’s information line on 1300 363 992.

It is important to note that, before the Privacy Commissioner will handle any complaint, the Commissioner is required to be satisfied that you have first raised any complaint with Betty Baxter and attempted to resolve the complaint in accordance with our Privacy Policy.

Betty Baxter will make every reasonable effort to resolve your complaint. Please lodge any complaint with the Privacy Officer. The Privacy Officer can be contacted in any of the ways set out in the “Access to your personal information” section of this Privacy Policy.

Any further questions?

If you have any questions about privacy or the security of your personal information, please contact our Privacy Officer. The Privacy Officer can be contacted in any of the ways set out in the “Access to your personal information” section of this Privacy Policy.

BY USING THE BETTY BAXTER WEBSITE YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU SHOULD NOT USE THIS WEBSITE.

BETTY BAXTER MAY UPDATE THIS PRIVACY POLICY FROM TIME TO TIME IN FUTURE. YOUR CONTINUED USE OF THIS WEBSITE FOLLOWING THESE UPDATES AND THE POSTING OF ANY CHANGES TO THIS POLICY WILL BE TAKEN AS YOUR ACCEPTANCE OF THESE CHANGES AND THE REVISED POLICY.