Privacy Statement - Australia and New Zealand

1. Privacy at Belgravia

1.1 Our Privacy Commitment

We recognise that providing personal information is an act of trust, which we take very seriously.

We are committed to protecting your privacy and for that reason we will only collect, use, disclose, store and otherwise handle your personal and sensitive information that is necessary for us to deliver goods and services to you, to employ you or for you to become a Belgravia managed facility or franchisee.

1.2 Our Privacy Statement

Due to the nature of our business it may be necessary to obtain personal information about you.

We will not collect or use any information you provide in an inappropriate manner.

We will only ask for and use personal information that we reasonably need to conduct our business and we will take all reasonable steps to protect your personal information from misuse, loss, unauthorised access or inappropriate disclosure.

This current policy came into effect at October 30, 2020. We may need to update it over time and will post the updated version on our website when updates occur.

1.3 What information we collect

We offer products and services across a mix of diverse industries, including health and fitness, leisure, tourism, property, finance, clothing and technology. We also offer employment across these businesses and manage numerous facilities directly or via franchisee.

The information that we collect about you will vary depending on the way in which you interact with our businesses; however, it is mostly information that is provided by you, such as your name, date of birth, contact details (including address, email address and any phone or mobile numbers), occupation/employment details, emergency contact details and financial information such as credit card or bank account details.

Depending on how you are using our products and services we may also collect more detailed information such as information about how you use our products and services:

• Details of guardian/s for minors;
• Details of participation in membership programs;
• Health information when accessing our venues or services where health status may be important;
• History of preferences, interests and behaviour relating to transactions, products, services and activity with our digital services;
• Your computer IP address when visiting any of our websites;
• Your image if required for membership identification;
• Records of your communications and interactions with us, such as details of your previous dealings with us or any of the Belgravia-managed facilities;
• If you apply for a job in one of our businesses, details about your education, employment history, membership of professional associations, referees, Working with Children status and next of kin.

We may collect some forms of sensitive information. This is most likely to be health information or information related to employment such as criminal history and professional associations.

Where we collect sensitive information from you, we will only do so with your consent. This information will only be used for the purpose it was collected or, in exceptional circumstances, to lesson a serious threat to a person’s health or safety.

You are not obliged to provide personal or sensitive information to us; however, we may not be able to provide goods or services to you if you don’t.

If you provide us with another person’s personal information, such as for the purchase of a gift voucher, you must have their consent to do so and we rely on you to have informed those individuals that you are providing their personal information to us and have advised them about this statement.

1.4 How we collect your information

We will never ask you to provide or verify your personal or sensitive information by clicking on a link, such as that of a member portal, and we will never ask you to email or fax credit card information. If you do receive such a request, we ask that you report it to us immediately.

We will collect your information in a variety of ways:

You provide it to us or one of our service providers when you interact with us to purchase our goods, use our services or to seek employment. This may occur in person, by phone, online or by completing agreements and application documentation and could take the form of:

• purchasing clothing,
• applying for or maintaining your membership at one of our facilities,
• completing a feedback form or survey,
• posting on our official social media pages,
• through payments you make,
• applying for a job, or
• applying to become a Belgravia managed facility or franchisee.

We collect information about how you interact with us, such as by email and our websites. This may occur via the use of cookies or other technology to identify your unique web browser when interacting with us online.

We also obtain information from outside sources like companies running competitions on our behalf and public information, such as your public posts on our official social-media pages.

We understand that you may not wish for us to collect your personal or sensitive information; however, we may not be able to provide goods or services to you if we don’t.

1.5 How and where we keep your information

The exact location where your information is stored or processed will depend on the part of our business that has collected it and the goods and services we provide you.

Generally, we hold your personal information electronically and in hard copy, both at our premises and at facilities owned and operated by our service providers. Digitally, Belgravia Group stores all customer and client information as well as all of its business data within Australia with no geo-redundancy. Additionally, personal information held by Bizwear is stored and processed in Australia only.

Your information is only accessed on a ‘need to know’ basis and this forms part of the controls we apply to protecting your personal information.

We use a combination of physical and technology controls, and internal procedures to keep your information safe. These controls include Tier-3 data centres, secured offices, locked files, password-protected computing, monitored firewalls, anti-virus software and encryption communication with our websites, membership portal (ActiveWorld) and apps.

We only keep your information for as long as we need it to deliver goods and services to you or as required by law, after which we will either destroy or de-identify your personal information.

1.6 How we use your information

We need to use your information to provide you with our products and services or to employ you. This may also extend to:

• Assisting with feedback or queries you may have;
• Processing bookings or applications that you submit;
• Conducting and administering swim, health club, golf or other memberships;
• Promoting and marketing, including direct marketing, for current and future businesses we conduct;
• Informing you of the products and services of our commercial partners;
• Processing and fulfilling gift vouchers;
• Surveys, direct marketing, promotions and competitions;
• Assessing applications for employment and ongoing management as an employee;
• Assessing applications to become a franchisee and/or contract partner;
• Accounting purposes, such as managing franchisee fees and royalties, and billing of services, products and memberships;
• Evaluation and improvement of the effectiveness of our website and official social media pages;
• Collecting diagnostic and statistical information relating to our IT systems;
• Facilitating our internal business operations, including the fulfilment of legal requirements and assessing new and/or improved services.

1.7 How we share your information

The extent to which we share your information will depend on which of our businesses collected it and which goods and services we provide you.

We may exchange your personal information with other parties who provide services to us. This may include sharing with:

• Our contract partners and franchisees to verify membership details, confirm bookings, administer gift vouchers or prizes, manage health and safety incidents and to provide you with goods and services;
• Third-party contractors who may be performing services for us that involves your personal information, such as mailing your membership card;
• Service providers who are engaged to provide us services relating to data processing, data analysis, online computing, printing, contract management, legal, accounting, business consulting, marketing, research, auditing, delivery, security and mailing services;
• Insurers and work cover in the case of a health-and-safety incident;
• Any other party with which we are legally required to share.

Our contract partners and franchisees may also provide your information to:

• Their third-party suppliers in order to provide you with additional services such as group purchase savings;
• Contracted assessors for assessment of the quality control standards of our franchisees.

We will not sell your information to marketing bodies without your consent.

1.8 How you can access or correct your personal information

We believe it is important to ensure that the personal information we hold about you is accurate and up to date. The accuracy of the information that we hold depends to a large extent on the information that you provide, so it is important that you make sure the personal information we hold about you is accurate, up-to-date and complete.

We request that you contact the relevant business or facility that you deal with if any of your personal information has changed or if you believe that any of your information is inaccurate. You also have a right to request a copy of the information that we hold about you. There is no charge to submit a request or to correct this information. To make such a request, see 1.11 How you can contact us.

1.9 What happens if your personal information is part of a data breach?

We recognise that providing personal information is an act of trust, which we take very seriously.

If we believe that your personal information has been subjected to an eligible data breach under the Notifiable Data Breaches scheme in Australia, we will notify you and the OAIC as required under law and in accordance with OAIC and our own internal processes.

If we believe that your personal information has been subject to a notifiable privacy breach under the Privacy Act in New Zealand, we will notify you and the Privacy Commissioner as required under law and in accordance with the Privacy Commissioner’s and our own internal processes.

1.10 How you can make a privacy complaint

If you have any disputes or complaints about the way in which your personal information has been handled by us, please contact us using the details information has been handled by us, please contact us using the details in 1.11 How you can contact us.

We will investigate any dispute or complaint and respond to you within a reasonable time. If you still consider that your privacy complaint has not been resolved, you may then take your complaint to the Office of the Australian Information Commissioner (OAIC) by visiting www.oaic.gov.au or calling 1300 363 992.

If your complaint is about a New Zealand site, you can contact the Privacy Commissioner by visiting www.privacy.org.nz.

1.11 How you can contact us

If you have any questions about this Privacy Statement, our management of your information or if you would like a copy of this statement, please contact us on the details below:

For Belgravia Health and Leisure Group, call 03 8727 7777 or email privacy@belgravialeisure.com.au;
For Bizwear, call 1300 363 265 or email customerservice@bizwear.com.au;
For all other Belgravia companies, email nlord@belgraviagroup.com.au.

1.12 Changes to this Statement

This Privacy Statement came into effect on November 19, 2020. Although most changes are likely to be minor, we may amend or update this Privacy Statement to ensure that we maintain the highest standards. If we do, we will post the updated version on our websites.

1.13 Your privacy rights

In Australia, the Privacy Act 1988 deals with your information privacy rights and how we must handle your personal information. The equivalent law in New Zealand, is the Privacy Act 2020 when it comes into force on 1st December 2020 and the Privacy Act 1993 until that time.

This current policy came into effect at October 30, 2020.