Compliance with Privacy Obligations

This Privacy Statement sets out the policy of Lentille Looking Ltd (What’s it all about… Pilates) and its franchisees with respect to the way in which we collect, use, disclose, store, secure and dispose of Personal Information about our customers, franchisees and employees including through our website at www.whatsitallabout.com.au

What’s it all about… Pilates is bound by the National Privacy Principles set out in Schedule 3 of the Privacy Amendment (Private Sector) Act 2000 (“the Act”). A copy of the National Privacy Principles may be obtained from the website of The Office of the Federal Privacy Commissioner at www.privacy.gov.au

What’s it all about… Pilates is dedicated to ensuring that personal and sensitive information is gathered with respect to the individual and aims to exercise the highest standard of care in preserving privacy of information in all areas of operation.

The information about individual health collected by What’s it all about… Pilates is handled in compliance with applicable State and Territory health records legislation.

Collection of Personal and Sensitive Information

For the purposes of this Statement, “Personal Information” is characterised as being information or an opinion about an individual whose identity is apparent or can reasonably be ascertained from that information or opinion. “Sensitive information” means health information about an individual.

The types of Personal Information generally collected by us include name, address, date of birth, mobile and telephone numbers, e-mail address, credit card or bank account details, occupation and employer, driver’s licence number and emergency contact details. Personal Information is also collected when individuals provide business cards or other documentation to us containing such Personal Information, including completion of a Membership Agreement and a Health Questionnaire. Personal Information also includes information we collect in the course of providing services to individuals and external communications.

The types of Sensitive Information generally collected by us include information relating to health issues that is necessary to properly advise customers about fitness training. The types of health related information include medical history, whether individuals are using medication, smoke or are pregnant and other health related information. We will obtain specific consent in circumstances where it is necessary to collect sensitive information.

Use of Personal and Sensitive Information

Any Personal or Sensitive Information that we collect about individuals will be used and disclosed by us to provide the services required or otherwise to enable us to carry out our functions.

What’s it all about… Pilates will disclose Personal Information to third party business partners when they provide services to What’s it all about… Pilates that are consistent with the terms of Privacy Policy. When we outsource or contract out specific support services, our contractors may access individuals’ Personal Information. It is important to note that all our contractors are subject to strict confidentiality obligations. We take great pride in operating only with reputable business partners.

Personal or Sensitive Information that is in our possession is not a subject to rent, sale or any other disclosure to any other company or organisation, without prior consent of individuals where that consent is required by law. Individuals consent to our use and disclosure of their Personal Information where it is incidental to a sale of our business to a third party. They also consent to Personal and Sensitive Information being disclosed to What’s it all about… Pilates support office, franchisees and placed on an intranet that is accessible by support office and all franchisees. This is required to enable individuals to be recognised as an What’s it all about… Pilates member, no matter which What’s it all about… Pilates Club they attend in Australia.

What’s it all about… Pilates will disclose personal information if it is under a legal requirement to do so (for example, under a court order, or if required under legislation), or if an authorised request is made from a law enforcement agency.

Otherwise, we will only disclose Personal Information with the consent of the relevant individuals. If consent is obtained, we may provide Personal Information to What’s it all about… Pilates’s personal trainers to assist customers to improve their fitness and well being, in addition, trainers can advise customers which fitness programs are suitable for them. If personal trainers are contractors (rather employees), their contracts with us require them to keep Personal Information confidential.

Information provided by Franchisees

Information of a personal and sensitive nature is provided to What’s it all about… Pilates by its potential franchisees. The information is used to evaluate the suitability of the applicants becoming What’s it all about… Pilates Franchisees. What’s it all about… Pilates may make enquiries and check accuracy of information at consent of potential franchisees, this will be the only time the Company may disclose such information to third parties unless required in accordance with the Privacy Act.

It is at the discretion of an applicant to provide information requested, however this may obstruct the process of assessing their suitability. The Personal Information of successful applicant will form part of an ongoing franchisee record. Should the application be unsuccessful, individual will be given the opportunity to have the information collected returned to you or destroyed.

Information provided by employees

Any employment application provided to the Company will be used solely for the purpose of analysing suitability for a position available. Personal details will only form part of an employee record if application is successful. The information about employees will only be disclosed by What’s it all about… Pilates if required by law to authorised government agencies i.e. Australian Taxation Office or as otherwise directed by employee.

Any unsuccessful applications will remain on file to be revisited should suitable opportunities arise in the future and if required by the applicant applications may be returned or destroyed.

Website/online privacy

The Privacy Policy outlines our approach to online privacy issues regarding Personal Information collected through our website: www.whatsitallabout.com.au

What’s it all about… Pilates will handle personal information collected online with the utmost care, and will not knowingly use it in ways not explicitly consented to by the user who supplied the information and to whom the information refers.

What’s it all about… Pilates will handle Personal Information collected online consistently with the way that it handles Personal Information collected offline. Other matters specific to our handling of Personal Information online are set out below.

1. a) Cookies
   No Personal Information is collected by What’s it all about… Pilates when individuals visit our website, unless they chose to provide it to us (for example, by sending us emails through our website). However, we may collect certain data that does not identify individuals (sometimes called “web log information”) when they visit certain pages (such as the type of browser and operating system they have). We may also use “cookies” which are small files that are stored on computer and that manage the security and navigation process of the site. Users can choose to block these cookies but some portions of the site may not function correctly if they do. This type of data is collected for statistical purposes only, and while cookies will identify a computer, they are unlikely to identify users personally.
2. b) Email/SMS marketing
   We will not distribute our marketing material via SMS unless customers have consented to this. This is a requirement of the Spam Act 2003. Further, customers can unsubscribe from our e-newsletter or other bulletins by using the “unsubscribe” facility contained in each electronic publication we send. Occasionally, What’s it all about… Pilates will send promotional email messages to prospective customers to market a service or activity. This will only be done on the reasonable belief that customers would be interested in the subject matter. In every case customers will be provided with clear and simple instructions on how to be removed from our mailing list
3. c) Site security policy
   Our website uses up-to-date technology to maximise the security of user’s Personal Information. What’s it all about… Pilates places great importance on the security of all information associated with our customers. Our security and privacy policy are continually reviewed and updated, the user information is accessed by authorised personnel. We aim to prevent accidental manipulation, destruction, use, disclosure loss or unauthorised access of data.
4. d) Hyperlinks to other websites
   Our web site contains links to other web sites which we do not control; they are not covered by our Privacy Policy. If users access other websites using the links provided, operators may collect information from users and use it in accordance with their privacy policy, which may differ from ours. We have no control over the types of information the site owners choose to collect and how they use it.
5. e) Social Networking Acceptable Use Policy
   What’s it all about… Pilates encourages all comments on any of our social networking pages (Facebook, YouTube, Twitter), as we would like to hear from our fans, clients, friends and staff. Customer views, news, ideas, insights and criticisms about What’s it all about… Pilates are very important to us, yet the social networking sites must not be used to abuse others, expose others to offensive or inappropriate content, or for any illegal purpose.

It is the user’s responsibility to protect their personal privacy when using our social networking pages. We advise users not to include any Personal Information of either themselves or of others in their posts to the wall (such as email addresses, private addresses or phone numbers).

In addition, it is recommended to refrain from posting materials to the page that infringe the intellectual property rights of others and not to include internet addresses or links to websites, or any email addresses in posts to the wall.

Any information posted to the What’s it all about… Pilates Social Networking pages (Facebook, YouTube, Twitter) is recorded and used for the purpose of administering pages and addressing any comments made, while no attempt will be made to identify users except where authorised by law.

We are not responsible for the privacy practices or content of social networking pages (Facebook, YouTube, and Twitter). The responsibility of What’s it all about… Pilates is limited to our own postings made on our Facebook page “What’s it all about… Pilates Australia”.

Security

We use all reasonable endeavours to secure any Personal or Sensitive Information that we hold and aim to keep this information accurate and up-to-date. Technical and organisational security measures are in place to ensure the security of information and to protect it against deliberate or accidental manipulation, destruction, use, disclosure loss or unauthorised access.

Personal and Sensitive Information is stored behind industry standard firewalls and where applicable, protected by user names and passwords. Where appropriate, Personal and Sensitive Information is kept within a locked storage room.

Changes to Privacy Statement

What’s it all about… Pilates reserves the right to change this Privacy Statement without prior notice. Any changes to Privacy Statement will be posted on the What’s it all about… Pilates website. In order to remain updated and informed on protection of Personal and Sensitive Information, we encourage users to review this Statement. If, at any time, you have questions, comments or concerns about our privacy commitment please contact us.

Access and correction of your Personal Information

The access to Personal Information that we and/or contractors hold can be obtained on request. It is at the discretion of What’s it all about… Pilates to provide this information to individuals, depending upon legal circumstances. Users are entitled to tell us if they do not wish us to hold their information, we will remove all such information from our database. Individuals also have the right to ask us to correct information about them which is inaccurate, incomplete or out of date.

If you wish to seek access to or correction of personal information that What’s it all about… Pilates holds about you, please contact us at pilates@whatsitallabout.com.au. We may ask you to put your request in writing. It is important to us that the Personal Information we hold about you is accurate, complete and up to date.

Contact details

You can provide a written request or complaint at one of our clubs, or you can contact our Privacy Officer as follows;

• By letter: Privacy Officer, What’s it all about… Pilates, Level 2 71 Longueville Rd, Lane Cove, NSW, 2066, Australia;
• By telephone: 02 9415 5300; or
• By email to pilates@whatsitallabout.com.au

This Privacy Statement applies to What’s It All About…  Pilates, its employees and contractors.
If we decide not to correct or provide you with access to your Personal Information, we will give you our reasons for our decision.

Complaints

If you have a complaint about the way we have dealt with your Personal Information, please contact us at the above telephone numbers.

We will make all reasonable attempts to respond to your complaints or requests.

CCTV Cameras and Surveillance

We undertake an ongoing video recording in every What’s it all about… Pilates gym for the purpose of ensuring security in every club via CCTV cameras, recording the time and date at which images are taken.

Video recordings can be accessed only by authorised staff.

Video recordings of a specific incident may be released to the NSW Police Service only under the terms of this policy or subject to the execution of a search warrant or other legal process and only with the approval of What’s it all about… Pilates Company Secretary.

This Privacy Statement contains specific provisions applicable to users using services in or accessing our Sites or Apps from Australia. Note, the main section of the What’s it all about… Pilates, LLC Privacy Policy shall continue to apply for Australia-based users. However, where any provisions in the main Privacy Policy conflict with this Privacy Statement, this Privacy Statement shall take precedence for Australia-based users only.