When you use our services, you’re trusting us with your information. We understand that this is a big responsibility and we work hard to protect your information and put you in control.
TABLE OF CONTENTS
Who we are
Information we collect
Information we collect via automated means
Third party pixels and cookies
How we use your personal information
Sharing personal information
Your marketing choices
Your privacy choices
International data transfers
How we protect information
Data breach procedures we have in place
Links to third-party websites
Residents in the United Kingdom or the European Economic Area
1 - WHO WE ARE
The Trustee of ELIA® Wellness Trust, trading as ELIA Wellness, is a registered charity and division of Adventist HealthCare Limited (AHCL) (ABN 76 096 452 925). This document sets out the principles that the Trustee of ELIA Wellness Trust (ABN 23 384 623 487) trading as ELIA Wellness (referred to as “ELIA, “ELIA Wellness”, “ELIA Lifestyle Medicine Centre”, “we,” “us,” and/or “our”) adopts in relation to the protection and handling of personal data (also referred to as “Personally Identifiable Information” or “PII”) that is collected from Individuals and Participating Organisations through various websites, mobile applications, events, programs and social profiles owned and operated by us, which include, but are not limited to eliawellness.com, elialmc.com, eliawellness.org. elia.events, elia.to, Wellness (Mobile App), Wellness Snapshot and ELIA Lifestyle Medicine Centre/s.
The Trustee of ELIA Wellness Trust is a registered Australian charity, ELIA is committed to protecting your personal information, and does so in accordance with the Australian Privacy Principles, which are set out in Schedule 1 of the Privacy Act 1988 (Cth), and any other applicable state or territory legislation.
For more information on our ACNC Charity Registration Details
ELIA Wellness is owned by AHCL who operate a number of healthcare businesses including the Sydney Adventist Hospital (known as The San or SAH) and San Day Surgery Hornsby. The San includes the teaching hospital, Sydney Adventist Hospital Clinical School (in collaboration with the Australian National University and Avondale University), San Pharmacy and San Diagnostics. San Diagnostics services include San Radiology and Nuclear Medicine and our partnership with San Ultrasound for Women. AHCL is Trustee for Sydney Adventist Hospital Trust and ELIA Wellness Trust.
2 - OVERVIEW
ELIA Wellness builds a range of physical and digital services that help people to discover, understand, and improve their whole-person health. Our services include:
Wellness questionnaires with results and recommendations
Self directed wellness programs via our websites and mobile applications
Facilitated wellness events and programs with digital group engagement via our websites and mobile applications
Physical and digital programs facilitated by our Lifestyle Medicine Centre/s
Wellness videos, articles and factsheets
Digital community group engagement
Fitness and exercise videos
Recipes and nutritional information
Logging and viewing health biometric data over time
Partner training, accreditation and event management tools
Events and programs facilitated by trained ELIA Partners
We collect information to provide better services to all our users - from figuring out basic stuff such as which language you speak, to more complex things like personalised wellness reports, or what content you are interested in. The information we collect, and how that information is used, depends on how you use our services and how you manage your privacy controls.
When you’re not signed in to an ELIA account, we store the information that we collect with unique identifiers tied to the browser, application or device that you’re using. This allows us to do things like maintain your preferences across browsing sessions, such as content you have already seen or search results based on your activity.
When you’re signed in, we also collect information that we store within your ELIA Account, which we treat as personal information.
3 - INFORMATION WE COLLECT
We ask for personal information so you can use our services, sign in to your account, receive customer support and safety information, and communicate with you about our services, promotions, and activities. We collect the following information when you engage with us.
When you create an account we collect:
Name and contact information
Date of birth
Username and password that you may select in connection with establishing an account on our Services
Wellness statistics which you provide to us in the areas of Whole-Person Health, Lifestyle Medicine and the 7 Dimensions of Wellness which includes Emotional, Physical, Social, Vocational, Spiritual, Intellectual and Environmental Wellness.
Emergency contact information
Your photograph, social media handle, or digital or electronic signature
Details of the products and services (such as product or membership options) you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your inquiries
Personal preferences such as topics of interest, product, partner and event feedback
Any additional information relating to you that you provide to us directly through our websites or by other means such as over the phone, via email, or in person
Information you provide to us via voluntary members feedback or engagement surveys;
Details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your inquiries;
Any additional personal information you provide to us, or authorise us to collect, as part of your interaction or membership with ELIA
When you buy products through ELIA or our partners, affiliates, and subsidiaries:
Billing information (e.g., credit card details)
Shipping information such as your address
When you use our Websites or Apps
Information on your interaction with our apps, web sites and advertisements such as pages you visit
Social media handles, content, and other information that you post to our social media pages or tag us on your social media pages, and information we obtain from third-party social media services (e.g., Facebook) if you choose to link to, or create or log in to your ELIA online account through these platforms
When you choose to sync or connect your devices
Health information with your consent (e.g. heart rate, calories, steps, distance, duration, location) collected from third-party devices (e.g. Apple Watch, Android Wear), apps or services (e.g., Apple Health, Google Fit, Samsung Health) when you consent to connect your device or account.
When you interact with us
Any additional information relating to you that you provide to us through our Services
Information you provide to us via voluntary members feedback or engagement surveys
Information provided when attending ELIA events or ELIA sponsored events (e.g., email address, professional affiliation)
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings
Communications between us
4 - EMAILS
When providing personal information via email to ELIA Wellness, please be aware that inherently, email messages can be viewed by other Internet users while in transit. Although this risk is usually quite small, if you have personal or other information to discuss, you may wish to contact the person by phone or mail.
4 - INFORMATION COLLECTED BY AUTOMATED MEANS
When you interact with our online services, we obtain certain information by automated means, such as cookies, web server logs, web beacons, and other technologies. A 'cookie' is a small text file that websites send to a visitor’s computer or other Internet-connected devices to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
We use these automated technologies to collect information about your equipment, devices, internet connection, browsing actions, and usage patterns. The information we obtain in this manner may include your IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, browsing history, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Sites. We may also obtain information about how you interact with our services, such as features and pages you visit, search queries, and download errors.
6 - THIRD PARTY PIXELS AND COOKIES
When you visit, register for or log in to our Services, cookies, web beacons, and similar technologies may be placed on our Services by our online data partners and vendors to associate these activities with information they or others have about you, such as email addresses, to help us to serve relevant marketing offers to you.
We do not sell your personal information or transfer personal information to third parties to use for their own benefit; however, we allow certain companies to place tracking technologies like cookies on our Services. Those companies receive information about your interaction with our Services that is associated with your browser or device and may use that data to serve you relevant ads on our Services or others. Except for this kind of sharing, we do not sell any of your information.
7 - HOW WE COLLECT YOUR PERSONAL INFORMATION
ELIA collects personal information reasonably necessary to carry out our business, to assess and manage our members' needs, and provide our Services to you. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing member relationships.
The purposes for which ELIA usually collects and uses personal information may include:
To fulfil obligations under a membership agreement and/or any other contract you may have with us;
To deliver the Services and/or products you requested;
To manage our relationship with you, with your consent, this may involve the use of health and wellness information from connected devices, apps or services;
To provide information and marketing about products, Services, and/or special offers to members;
To obtain opinions or comments about products and/or Services from members;
To record statistical data for marketing analysis from members;
To improve our Services to members, as well as for training and quality purposes;
Responding to requests, questions, complaints, and other general inquiries;
Managing, planning, advertising, and administering programs, events, competitions, and performances;
Researching, developing and expanding our facilities and Services;
At your direction and with your consent;
Information to provide you with access to events (e.g., for certain events, we may require professional licensure information);
For quality control and administration and assisting us to develop new and improved products and Services;
To recruit volunteers, interns, staff, and employees;
To comply with any requirement of any applicable statute, regulation, rule, and/or good practice;
To fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s) from time to time;
You may need to provide personal information in order to use some of the wellness tools at our events, our clinics or on our site/s and mobile applications. This information may include your answers to questions about your health status. We use this information to calculate your personalised answer
8 - SHARING PERSONAL INFORMATION
ELIA is owned by AHCL which owns various healthcare businesses of which are Participating Organisations. We integrate and share your information with various Participating Administrations to allow us to perform the various duties discussed above and provide you with valuable Services. Whenever we are required to do so, we shall take steps to ensure that necessary level of protection, so the disclosure will occur in compliance with applicable laws and regulations. We may share your personal information for the purposes as follows:
Within our company and with our affiliates
With service providers that perform Services on our behalf, including for the purposes of operating our website, assisting us to perform business functions, managing and updating member lists and records, analysing data, handling billing and payments, and facilitating customer service.
With professional services such as legal advisors, accountants, and consultants;
With select partners we may collaborate with;
With other parties with your consent and at your direction; and
We reserve the right to disclose your personal information as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request, or legal process served on us, or to protect the safety, rights, or property of our customers, the public, us or others.
9 - DATA RETENTION
We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. When we no longer need the personal information we collect, we either anonymize the information upon your request or securely destroy the information, unless we are legally required to retain it.
10 - MEDICAL RESEARCH
ELIA organises, manages and participates in ongoing Lifestyle Medicine Research. The data collected by our services is de-identified for the purpose of use in medical research. The data is considered Non-PII, as no information that can identify an individual, including but not limited to name, contact details, street, or relationships, is included in the research data. ELIA Research is not a third party, and compromises as an ELIA Wellness activity..
ELIA Wellness holds the data in isolation from all public engagement platforms, and there is no capacity to track, trace, or connect the lifestyle data back to an individual. The act of holding an ELIA account and using ELIA products and services, constitutes a users authority for ELIA to de-identify and use data in medical research.
For members of the United Kingdom or the European Economic Area (“EEA”), the retention of Non-PII data for medical research complies with General Data Protection Regulation Article 89; Safeguards and derogations relating to processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
11 - CHILDREN’S PRIVACY
We do not knowingly collect any personal information from children under the age of 13. If a user is identified as a child under the age of 13 through a support request, we will not collect, store or use such personal information, and any personal information that has been provided will be deleted.
12 - YOUR MARKETING CHOICES
You can opt-out of our use and disclosure of your personal information for marketing purposes and customer satisfaction surveys, and/or withdraw your prior consent for the same, by the methods provided below. Upon requesting an opt-out, your consent will be withdrawn; however, please note that it often takes some time to process these requests. Therefore, it is possible that you may receive communications scheduled prior to our receipt of your withdrawal of consent.
You may reply to a promotional or marketing email that you have received from us with the word "Unsubscribe" in the subject line or you can email us directly at [email protected]. You may also unsubscribe from receiving marketing or other commercial emails by following the instructions included in the email. (If you use more than one email address, then send your opt-out email from each of your e-mail addresses.) Another way to unsubscribe is to delete your ELIA account in the app but this is irreversible, and you will lose access to your account and records. You would also need to cancel your subscription to avoid ongoing subscription charges. We may also provide additional methods for you to opt-out of having your personal information used or disclosed for promotional and marketing purposes.
13 - YOUR PRIVACY CHOICES
You may have certain rights and choices regarding our processing of your personal information. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right to:
Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared
Access a copy of the personal information we retain about you
Update any inaccuracies in the personal information we hold about you
Request deletion of your personal information
Request that we transfer your information to another entity in the format in which we maintain it in the ordinary course of business
Object to the processing of your personal information
Restrict how we use your personal information whilst a complaint is being investigated
We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorised representatives to exercise rights with respect to that information. If you are an authorised agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorised to make that request.
Under some circumstances, we will use your email address on file to verify your identity. We may also request additional information. For example, if we suspect an access request is fraudulent, we will request additional information in order to verify your identity.
We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will endeavour to inform you of the denial, provide an explanation of our actions, and the reasons for the denial.
We will not restrict or deny you access to our Services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver the Services.
Where you have consented to our processing of your personal information, you have the right to withdraw, at any time, any consent that you have previously given to us for use of your personal information. In certain circumstances even if you withdraw your consent we may still be able to process your personal information if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations. To make a request to exercise any of these rights (where applicable) in relation to your personal information, please contact us using the contact details below.
If you wish to contact us to make a request in connection with your personal information we have or to inquire or provide feedback about our privacy practices, you can email us directly at [email protected].
Your exercise of the rights described above is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
You may make a complaint about privacy to the Privacy Officer at the contact details set out below. We may ask you to provide further information about your complaint and the outcome you are seeking.
If you are not satisfied with our response to your complaint, or you consider that ELIA may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website.
With respect to individuals located in the United Kingdom or the European Economic Area (“EEA”), where we are unable to resolve an inquiry or a complaint, you have the right to contact the data protection regulator in the European country in which you are based.
14 - INTERNATIONAL DATA TRANSFERS
We may transfer personal information from the United Kingdom or the European Economic Area (“EEA”) to countries that the United Kingdom’s Secretary of State or the European Commission (as applicable) has deemed to adequately safeguard personal information, in which case no additional safeguards are required in order to transfer this information. If we transfer your personal information to other countries, we will either transfer it subject to the recipient’s compliance with standard contractual clauses, Binding Corporate Rules, or with your consent to the transfer, unless we are permitted by law to transfer personal information without such formalities.
15 - HOW WE PROTECT INFORMATION
We maintain administrative, technical and physical safeguards designed to protect personal information we maintain against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.
Despite such efforts, however, please note that no organisation can fully eliminate risks or guarantee the security of personal information. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of information about you at any time, and we bear no liability for uses or disclosures of personal information or other data arising in connection with the theft of the information or other malicious actions.
16 - DATA BREACH PROCEDURES WE HAVE IN PLACE
If ELIA becomes aware of an actual or potential unauthorised access to or disclosure of your personal information, we will manage the unauthorised access in accordance with the Notifiable Data Breach requirements under Part 3C of the Privacy Act. This may include notifying both you and the Privacy Commissioner where that breach is likely to result in serious harm as defined by the Privacy Act.
17 - LINKS TO THIRD PARTY WEBSITES
19 - CONTACT US
Email [email protected]
Phone +61 2 9847 3242
Or write to The Privacy Officer, ELIA Wellness, 148 Fox Valley Road (Locked Bag 2014), Wahroonga, NSW, 2076, AUSTRALIA.
20 - RESIDENTS IN THE UNITED KINGDOM OR THE EUROPEAN ECONOMIC AREA
You have explicitly agreed to us processing your information for a specific reason;
The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
The processing is necessary for compliance with a legal obligation we have; or
The processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
a) To prevent fraud;
b) To protect our business interests;
c) To ensure that complaints are investigated;
d) To evaluate, develop or improve our products; or to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.