PRIVACY POLICY
Application
The Privacy Policy applies to personal information collected by R & C Salter Holdings Pty Ltd trading as Vertex Training as the
business is an applicable organisation under the Privacy Act 1988 (Cth), which governs the way private sector organisations
collect, use, keep secure and disclose personal information.
The Privacy Policy outlines:
how and when Vertex Training collects personal information; how Vertex Training uses and discloses personal information; how Vertex Training keeps personal information secure, accurate and up-to-date; how an individual can access and correct their personal information; and how Vertex Training will facilitate or resolve a privacy complaint. We recommend that you read and understand the Privacy Policy and keep it for future reference. If you require any clarification, you can contact us on the address at the end of the document.
1. Personal information
1.1. What is Personal Information? a) Personal information is defined under the Privacy Act 1988 to mean information or an
opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is reasonably
identifiable, from the information or opinion. b) Some examples of personal information are your name, residential address,
email address, bank details, photos and opinions on your likes and dislikes that can identify you (see paragraph 3.2 below). c)
You do not need to identify yourself when you deal with us (e.g. when enquiring about membership) but there are certain
situations where we will only deal with individuals who identify themselves (e.g. providing fitness services).
2. Sensitive Information
2.1 What is Sensitive Information? a) Sensitive information is a subset of personal information. b) It means information or
opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or
affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual
orientation or practices, criminal record, health information about an individual, genetic information, biometric information that
is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
2.2 Collection of Sensitive Information a) In general, we attempt to limit the collection of sensitive information we may collect
from you, but depending how you use our products and services this may not always be possible and we may collect sensitive
information from you in order to carry out the services provided to you. b) The type of sensitive information we may collect
from you or record about you is dependent on the services provided to you by Vertex Training and will be limited to the
purpose(s) for which it is collected. c) We do not use sensitive information to send you Direct Marketing Communications (as
defined in paragraph 7 below) without your consent. d) We will not collect sensitive information from you without your consent
unless consent is not required by law.
2.3 Consent to collection of certain types of sensitive information We may collect certain types of sensitive information where
you have consented and agreed to the collection of such information. We will obtain your consent at (or around) the point in
time in which we collect the information unless consent is not required by law. The main type of sensitive information that we
may collect (if any) will usually relate to your: a) health or medical information; b) current or previous membership of a health
and fitness facility (if any); c) biometric identification, such as finger print scans; d) racial origin and religious beliefs, to the
extent these are ascertainable from any photographic identification (such as a driver’s licence or photo identification); e) family
health and medical history; but only if the sensitive information is necessary for, or incidental to, the purposes of collection set
out in paragraph 4.
3. Collection of your personal information
3.1 We will only collect personal information that is necessary for us to provide our products and services to you. This depends
ultimately upon the purpose of collection and we have set out the general purposes of collection at paragraph 4 below.
3.2 The type of information includes (but is not limited to) the following: a) your contact information such as full name (first and
last), e-mail address, current postal address, delivery address (if different to postal address) and phone numbers; b) your date
of birth; c) proof of your identity (including, but not limited to, driver’s licence, passport, birth certificate); d) any sensitive
personal information listed in paragraph 2.3; e) emergency contact details; f) whether you participated in any activity or event
organised by the club; g) photographs or video footage taken at our premises, which may include you; h) your opinions,
statements and endorsements collected personally or via surveys and questionnaires, including but not limited to your views on
the products and services offered by the club; and i) if you are requesting products or services from us or we are purchasing
goods or services from you, then any relevant payment or billing information (including but not limited to bank account details,
direct debit, credit card details, billing address, repayment information and invoice details).
3.3 As far as possible or unless provided otherwise under this privacy policy, we will collect your personal information directly
from you. If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we
have done this and the reason for it.
3.4 When you engage in certain activities, such as entering a contest or promotion, filling out a survey or sending us feedback,
we may ask you to provide certain information, which you may withhold or provide at your own discretion. It is optional for you
to engage in these activities.
3.5 Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified
as mandatory or voluntary. If you do not provide the mandatory data or any other information we require in order for us to
provide our services to you, we may be unable to provide or effectively provide our services to you.
3.6 If you use our website or mobile app, we may utilise “cookies” and “web beacons” which enable us to monitor traffic
patterns and to serve you more efficiently if you revisit our website / mobile app. A cookie or web beacon does not identify you personally but may identify your internet service provider, computer or mobile device. You can set your browser or mobile
device to notify you when you receive a cookie or web beacon and this will provide you with an opportunity to either accept or reject it in each instance.
4. Use and disclosure of your personal information
4.1 We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to
and/or as set out below.
4.2 You consent to us using and disclosing your personal information to facilitate a purpose in connection with: a) if required,
the verification of your identity, including the verification of your date of birth, if applicable; b) facilitating membership or
facility usage requirements; c) provision of our products and services to you, which shall include but is not limited to: i. the
administration and management of our products and services, including charging, billing, credit card authorisation and
verification, checks for financial standing, credit-worthiness (including but not limited to undertaking an assessment for credit
loss and obtaining credit references, if applicable), fraud and collecting debts; and ii. to offer you updates, or other content or products and services provided by Vertex Training that may be of interest to you; d) to facilitate the administration,
management and improvement of the club, including but not limited to: i) the use of your personal information collected in accordance with paragraph 3.1 in the administration and management of the club; ii) the management, governance and
administration of the club, including but not limited to any management and governance meetings of the club; e) if applicable, any requirement to include you in various registers maintained by the club including, but not limited to, the register of excluded persons; f) facilitating medical assistance in the event of a medical emergency, or to provide you with medical treatment as requested by you; g) your participation in any activity or event organised by Vertex Training including those delivered outside
the facility and administered by a third party organisation; h) co-ordinating, managing and maintaining good order and security of the club and our premises, which shall include but is not limited to protecting the rights and safety of other parties on our
premises; i) investigating and reporting information to third parties regarding any accidents or incidents that may have occurred on our premises; j) the improvement of our services (including to contact you about those improvements and asking you to
participate in surveys about our products and services); k) the maintenance and development of our products and services, business systems and infrastructure; l) marketing and promotional activities by us and our related bodies (including by direct mail, telemarketing, email, SMS and MMS messages) such as print or electronic newsletters; m) to provide customer service functions, including handling customer enquiries and complaints; n) to offer you updates, or other content or products and
services that may be of interest to you; o) our compliance with applicable laws; p) the transfer, and matters in connection with
a potential transfer, of the club to another entity; and q) any other matters reasonably necessary to continue to provide our products and services to you.
4.3 We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:
a) when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose (secondary use); b) if we reasonably
believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or
safety or to lessen or prevent a threat to public health or safety; c) if we have reason to suspect that unlawful activity has been,
or is being, engaged in; or d) if it is required or authorised by law or formally requested by a statutory or regulatory authority.
4.4 In the event we propose to use or disclose such personal information other than for reasons in 4.1, 4.2, and 4.3 above, we
will first seek your consent prior to such disclosure or use.
4.5 If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us via the details set out at the end of this document and we will ensure the relevant communication ceases. Any other use or disclosure we make of your personal information will only be as required by law or as permitted by the Privacy Act 1988 or by this privacy policy or otherwise with your consent.
5. The types of organisations to which we may disclose your personal information
5.1 We may disclose your personal information to other organisations. Examples of organisations and/or parties that your
personal information may be provided include a) related entities and subsidiaries of the club; b) our contractors and agents,
including but not limited to our professional advisors such as accountants, solicitors and auditors or other companies who assist
us in providing our products and services to you.
5.2 Your personal information is disclosed to these organisations and/or parties only in relation to the goods or services we
provide to you or for a purpose permitted by this privacy policy.
5.3 We take such steps as are reasonable to ensure that these organisations and/or parties are aware of the provisions of this
privacy policy in relation to your personal information.
6. Photographs, Videos and Closed Circuit Television
6.1 We use closed circuit televisions (CCTV) at certain locations throughout our premises (e.g. entry and exit) and surrounding
areas. The CCTV is integral to our security system and CCTV images are stored for a minimum “retention period” of 28 days
(unless an incident is identified, in which case the images are archived and retained for a minimum period of one year after the
retention period unless they are given to the relevant authority (e.g. police). The CCTV footage must be archived if requested by
the relevant authority. (Note: If an incident occurs at the venue, CCTV footage for the period leading up to, during and following
the incident must be archived and where no incident has been identified, the CCTV footage is automatically deleted within 30
days after the retention period.)
6.2 As indicated in paragraph 3.2(g), we may take photographs of you attending our premises, and we may wish to use them for marketing and advertising purposes. If we notify you of the collection and purpose at the time, unless you advise us otherwise, you expressly agree and consent to the use of any photographs, which may include you, for the aforementioned purposes, without compensation.
7. Direct Marketing
7.1 You expressly consent to us using your personal information, including any email address you give to us, to provide you with
information and to tell you about our products, services or events or any other direct marketing activity (including third party
products, services, and events) which we consider may be of interest to you.
7.2 You expressly consent to us disclosing your personal information to other organisations (including but not limited to
organisations such as those listed in paragraph 5.1) that may also use your personal information for sending you Direct Marketing Communications.
7.3 If at any time, you do not wish to receive any further Direct Marketing Communications from us, or others under paragraph
7.2, you may ask us not to send you any further information about products and services and not to disclose your information to
other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the email or by
contacting us via the details set out at the end of this document.
8. Cross Border Disclosure
8.1 Any personal information that you provide to us may be transferred to, and stored at, a destination outside Australia,
including but not limited to New Zealand and the United Kingdom, where we may utilise overseas data and website hosting
facilities or have entered into contractual arrangements with third party service providers to assist us with providing our goods
and services to you. Personal information may also be processed by staff or by other third parties operating outside Australia
who work for us or for one of our suppliers, agents, partners or related companies.
8.2 By submitting your personal information to us, you expressly agree and consent to the disclosure, transfer, storing or
processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that
countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal
information. However, we will take steps to ensure that your information is used by third parties securely and in accordance
with the terms of this privacy policy.
8.3 The Privacy Act 1988 requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of
your personal information outside of Australia do not breach the privacy principles contained within the Privacy Act 1988. By
providing your consent, under the Privacy Act 1988, we are not required to take such steps as may be reasonable in the
circumstances. However, despite this, we acknowledge the importance of protecting personal information and have taken reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this privacy policy.
8.4 If you do not agree to the transfer of your personal information outside Australia, please contact us via the details set out at
the end of this document.
9. Data quality and security
9.1 We have taken steps to help ensure your personal information is safe. You will appreciate, however, that we cannot
guarantee the security of all transmissions or personal information, especially where the Internet is involved.
9.2 Notwithstanding the above, we will take reasonable steps to: a) make sure that the personal information we collect, use or
disclose is accurate, complete and up to date; b) protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and c) destroy or permanently de-identify
personal information if it is no longer needed for its purpose of collection.
9.3 However, the accuracy of personal information depends largely on the information you provide to us, so we recommend
that you: la) et us know if there are any errors in your personal information; and b) keep us up-to-date with changes to your
personal information (such as your name or address).
10. Access to and correction of your personal information
10.1 You are entitled to have access to any personal information relating to you which we possess, except in some exceptional
circumstances provided by law (e.g. secrecy provisions under the Anti-Money Laundering and Counter Terrorism Financing
Laws). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete,
irrelevant or misleading.
10.2 If you would like access to or correct any records of personal information we have about you, you are able to access and
update that information (subject to the above) by contacting us via the details set out at the end of this document.
11. Consent
11.1 You are agreeing to the terms of this privacy principle if you visit the club, use our website or by accepting the terms of one of our terms and conditions (relating to a product or service offer) which refer to this privacy policy.
11.2 We reserve the right to modify the privacy policy as our business needs require. Changes to this policy as our business
evolves, our business processes and policies will be reviewed and may be amended. We may change this policy at any time. We will notify you of any change by posting an updated version of the policy on our website. Please be aware that it is your
responsibility to check our website and make sure you keep up-to-date with any changes to this policy.
12. Resolving Privacy Complaints
12.1 We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all
complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is
made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.
12.2 If you have any inquiries, concerns or complaints about the manner in which we have collected, used or disclosed and
stored your personal information, you can tell us by contacting us.
Telephone: 0431 415 868
Email: info@vertextraining.com.au
Postal Address: 1/28 Taree Street, Burleigh Heads, QLD, 4220
Please mark your correspondence to the attention of the Facility Manager.
12.3 In order to resolve a complaint, we:
a) will liaise with you to identify and define the nature and cause of the complaint;
b) may request that you provide the details
of the complaint in writing;
c) will keep you informed of the likely time within which we will respond to your complaint; and
d) will inform you of the legislative basis (if any) of our decision in resolving such complaint
12.4 We will keep a record of the complaint and any action taken in a privacy register.
12.5 Persons can refer their complaint to the Office of the Australian Information Commissioner if they are not satisfied with the
result of their complaint.
Date of Effect: June 30, 2021
Club Name: Vertex Training
Address: 1/28 Taree Street, Burleigh Heads, QLD, 4220
Contact details: info@vertextraining.com.au