Privacy policy

1.   About this privacy policy

This document sets out the policy, relating to the privacy of your personal information (Privacy Policy), of CWG Investments Pty Ltd (ACN 612 517 781) and its related entities including but not limited to CWG Shared Services Pty Ltd (ACN 615 193 489), CWG Massage Pty Ltd (ACN 610 676 652), CWG OTF Pty Ltd (ACN 614 111 410), CWG Sales & Brokerage Pty Ltd (ACN 615 196 140) and Collective Media Pty Ltd (ACN 160 970 141) collectively, CWG.

CWG is committed to protecting the privacy of the personal information it collects and receives.

This Privacy Policy applies to all your dealings with CWG whether at CWG head office, via CWG or its related entities websites or at franchised brand locations.

This Privacy Policy seeks to explain:

  • the kinds of personal information CWG collects & holds;
  • how CWG collects and holds your personal information;
  • why CWG collects, holds, uses and discloses your personal information;
  • how you may access and seek the correction of your personal information as held by CWG;
  • how you may complain about a breach of the Australian Privacy Principles (APPs) or a registered APP code (if any) that CWG are bound by, and how CWG will deal with such a complaint; and
  • if CWG is likely to disclose your personal information to overseas recipients and the countries in which such recipients are likely to be located (if it is practicable to specify those countries in this policy).

By using CWG’s or its related entities’ websites, completing any membership application forms, competition entry forms and filling any forms in the franchisee recruitment process, or otherwise making available personal information to CWG or its related entities in any way, you accept this Privacy Policy and expressly consent to CWG’s collection, use and disclosure of your personal information in the manner described in this Privacy Policy.

2.   Your Personal Information

CWG only collects personal information (being information that identifies or could reasonably identify an individual) where CWG considers it to be reasonably necessary for CWG’s functions and activities.

CWG collects personal information to deliver our products and services to franchisees, potential franchisees and members including in circumstances when:

  • processing and managing membership and franchisee applications;
  • facilitating members & casual members access to franchised brand outlets, including the provision of services;
  •  conducting marketing activities, research & special offers;
  • accurately identifying who is using CWG’s services;
  • communicating with members, franchisees & website visitors to CWG’s and its related entities websites and online enquiries;
  • profiling our members & their interests;
  • operating CWG’s business; and/or
  • transferring memberships and making membership services available between franchised brand outlets.

The types of personal information CWG collects includes:

  • name, age, gender, date of birth & next of kin;
  • health information (height, weight, medical conditions);
  • license and banking details;
  • contact details (including phone, fax and e-mail);
  • views and opinions; and
  • responses to forms and surveys (if any). 

3.   Your Sensitive Information

Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.

It is CWG’s policy to only collect your sensitive information where it is reasonably necessary for CWG’s functions or activities and either you have consented or CWG are required or authorised under law to do so.

The types of sensitive information CWG generally collects includes information relating to health issues that is necessary to properly provide customers with fitness, massage and related services. The types of health related information include medical history, whether individuals are using medication, are pregnant and other health related information.

4.   How CWG collects your personal information

CWG will solicit your personal information by lawful and fair means directly from you unless it is unreasonable or impracticable to do so.

CWG will collect directly personal information:

  • by email;
  • over the telephone (including calls and SMS);
  • via social media and over the internet (including surveys);
  • by written correspondence (such as letters, faxes);
  • on hard copy forms (including registration forms, application forms, competition entry forms and surveys);
  • in person;
  • through the CWG website (online purchases, web form submission or participation in a live chat);
  • electronic systems such as applications; and
  • through CWG’s security surveillance cameras.

 CWG may collect information from third parties including:

  • market researchers & direct marketing providers;
  • parents or guardians of underage members;
  • our current members (refer a friend);
  • the Australian Tax Office (ATO) and the Australian Securities and Investment Commission (ASIC); and
  • public sources (directories, membership lists, professional and trade associations, ASIC, bankruptcy or court registry searches). 

 

5.    Employment Applications / Employee Information

Any employment application provided to CWG will be used solely for the purpose of analysing suitability for a position available. Generally the types of personal information collected is the information included in the employment application. With an applicant’s consent, CWG may obtain sensitive information such as information about health or any criminal record. Any unsuccessful applications will remain on file to be revisited should suitable opportunities arise in the future or, if required by the applicant, applications may be returned or destroyed.

Employees’ personal information will only be disclosed by CWG if required by law to authorised government agencies e.g. Australian Taxation Office or as otherwise directed by the employee.

6.   Unsolicited personal information

Unsolicited personal information is personal information CWG receives that CWG has taken no active steps to collect (such as a job application sent to CWG by an individual on their own initiative, rather than in response to an advertisement).

CWG may keep records of unsolicited personal information if the information is reasonably necessary for one or more of CWG’s functions or activities. If not, it is CWG’s policy to destroy the unsolicited information or ensure that the information is de-identified, provided it is lawful and reasonable to do so.

7.   Using your personal information

The main purposes for which CWG collects, holds, uses and discloses personal information are to provide services and benefits to members, and to grow CWG’s membership.

CWG can use your information to:

  • process applications for memberships, franchisees & prospective franchisees;
  • understand CWG members’ needs and requirements;
  • manage & run CWG’s website & social media platforms;
  • provide you with information about CWG’s services;
  • delivering or enhancing CWG’s products and services;
  • help CWG maximise the benefits provided to members;
  • any other purpose directly related to CWG’s business and for which you have provided consent (where it is reasonably required by law).

CWG’s website requires subscriptions or registrations to use certain services, functions or content. You will know what information is being collected via these processes when you complete the relevant forms and provide the required details prior to submitting the application. CWG will collect data relating to any transactions you carry out through CWG’s website and the fulfilment of your order.

CWG may also use your data to monitor for any unauthorised use of CWG’s website, content or subscriptions to CWG’s services.

8.   Purpose of collection

If CWG collects personal information for a purpose (the primary purpose), CWG will not use or disclose the information for any other purpose (the secondary purpose) unless:

  • you would have consented to the use or disclosure of the your personal information; or
  • in relation to the use or disclosure of your personal information:
  • CWG’ contracted service providers including:
    • you would reasonably expect CWG to use or disclose your information for the secondary purpose and the secondary purpose is directly related to the primary purpose (sensitive information) or related to the primary purpose (not sensitive information);

    • use or disclosure is required or authorised under Australian law or a court/tribunal;

    • a permitted situation exists in relation to CWG’s use or disclosure of the information;

    • a permitted health situation exists in relation to use or disclosure of the information; or

    • CWG reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

 If CWG uses or discloses your information because CWG reasonably believes that the use or disclosure of your information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body, CWG will make a written note of the use or disclosure.

9.   Do you have to provide personal information?

You can refuse to provide personal information. However a refusal may mean that the service you requested is not provided or membership will be refused or forfeited.

10.   Sharing your personal information

CWG may use and disclose personal information for related purposes to third parties. Types of organisations to whom CWG may disclose your personal information includes:

  • CWG’s related entities;
  • government bodies such as ATO, ASIC, Australian Prudential Regulatory Authority and the police or courts (as required by law);
  • various law enforcement agencies and governments for security, customs and immigration purposes;
  • banking service providers;
  • rewards partner program providers;
  • physical fitness instruction;
  • beauty treatment and massage therapy service contractors;
  • professional or government organisations; and
  • CWG’ contracted service providers including:
    • information technology service providers;
    • planning research and development providers;
    • conference organisers;
    • marketing and communications agencies;
    • mailing houses, freight and courier services;
    • printers & distributors of marketing material;
    • debt collectors and banks; and
    • external advisers (recruiters, auditors & lawyers).

CWG does not rent, sell or exchange your personal information to third parties without your prior approval.

11.   Government Identifiers

CWG does not adopt, use or disclose government related identifiers (such as a Medicare number or licence number) as CWG’s own identifier for you unless:

  • it’s required/authorised by law or court/tribunal order;
  • it’s reasonably necessary to verify your identity;
  • it’s reasonably necessary to fulfil CWG’s obligations; or
  • CWG reasonably believes it is reasonably necessary for one or more enforcement related activities.

12.   Cookies

To improve CWG’s services, CWG may sometimes collect de-identified information from web users. The information collected does not identify an individual but does help CWG to analyse and improve its web services.

When you visit CWG’s website, a record of your visit may be logged and the following data may be supplied by your browser:

  • your IP address and/or domain name;
  • your operating system (type of browser & platform);
  • the date, time and length of your visit; and
  • the resources you accessed or downloaded.

CWG uses this information to customise the website for visitors and to collect data for analysis, quality control, administration and improving the website. It is not used for any other purpose. Aggregated data may be shared with third parties.

You can stop your browser from accepting new cookies or disable cookies altogether by changing your browser preferences.

13.   Links to other websites

Links to third party websites that CWG does not operate or control are provided for your convenience. CWG is not responsible for the privacy or security practices of those websites. Third party websites should have their own privacy and security policies which CWG encourages you to read before supplying any personal information to them.

14.   Direct Marketing

If CWG holds your information, CWG may use or disclose that information (other than sensitive information) for direct marketing if:

  • CWG collected the information from you; and
  • you would reasonably expect CWG to use or disclose the information for that purpose; and
  • CWG provided you with a simple way to opt out of receiving direct marketing from CWG; and
  • you have not made such an opt out request to CWG.

CWG may also use or disclose your information (other than sensitive information) for direct marketing if:

  • CWG collected the information from you and you would not reasonably expect CWG to use or disclose the information for that purpose or someone other than you; and
  • either:
    • you have consented to the use or disclosure of the information for that purpose; or

    • it is impracticable to obtain that consent; and

  • CWG provided you with a simple way to opt out of receiving direct marketing from CWG; and
  • in each direct marketing communication with you:
    • you have consented to the use or disclosure of the information for that purpose; or

    • CWG includes a prominent statement that you can request to opt out; or

    • CWG otherwise draw your attention to the fact that you can request to opt out; and

    • you have not made such a request to CWG.

CWG can use or disclose your sensitive information for the purpose of direct marketing if you have consented to the use or disclosure of that information for direct marketing.

If CWG has collected the personal information that CWG used to send you direct marketing material from a third party, you can ask CWG to notify you of its source of information. It is CWG’s policy to do so unless it is unreasonable or impracticable.

15.   How to opt out of direct marketing

If CWG uses or discloses your personal information for the purpose of direct marketing, you may request not to receive direct marketing communications from CWG.

If CWG uses or discloses your personal information for the purpose of facilitating direct marketing by other organisations, you may request that CWG does not use or disclose your information for this purpose.

CWG will give effect to your request not to receive direct marketing from CWG or an entity facilitated by CWG free of charge within a reasonable time after the request is made.

16.   Collection Notices

At or before the time of collection of personal information from you, or as soon as practicable afterwards, CWG will take reasonable steps to notify you or to otherwise ensure that you are aware of certain matters. CWG will generally include these matters in a collection notice. For example, where personal information is collected on a paper or website form, CWG will include a collection notice, or a clear link to it, on the form or a separate follow up communication.

Collection notices may provide more specific information than this Privacy Policy in relation to particular collections of personal information. The terms of this Privacy Policy are subject to any specific provisions contained in collection notices and in terms and conditions of particular offers, products and services. CWG encourages you to read those provisions carefully.

17.   Protecting your personal information

CWG stores information in different ways, including paper and electronic form. CWG takes reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure including:

  • secure password protected databases for storage;
  • confidentiality requirements of staff;
  • servers kept at a secure location with limited access;
  • document storage security requirements;
  • granting access only to verified individuals;
  • access controls for CWG’s buildings;
  • limited the provision of personal information to third parties and subject to guarantees about use; and
  • training staff to deal with the information.

CWG cannot guarantee that personal information will be protected against unauthorized access or misuse and CWG does not accept any liability for the improper actions of unauthorised third parties.

CWG will retain your personal information for as long as necessary to fulfil CWG’s obligations to you, to protect its legal interests, to comply with laws or as otherwise stated to you when CWG collects your personal information.

Once CWG is no longer required to retain your personal information, CWG will take reasonable steps to destroy your personal information or to ensure that your personal information is de-identified.

18.   Disclosing your personal information overseas

CWG may disclose your personal information to other third party service providers operating outside Australia who work with CWG or one of CWG’ suppliers, related companies, agents, or partners, or its master franchisor.  CWG may also store your personal information on servers based overseas or in the “cloud” or other types of networked or electronic storage.

Before disclosing your personal information to an overseas third party, CWG will first take reasonable steps to ensure that the overseas recipient:

  • does not breach the APPs in relation to your personal information; or
  • the recipient of the information is subject to a law, or binding scheme, that has the effect of protecting your personal information in a way that is substantially similar to the way in which the APPs protect the information.

Personal information may be disclosed by CWG to other CWG entities and third parties in jurisdictions including Australia, Canada and the United States of America.

To make it easy for you to deal with CWG and other CWG entities and provide you with a more personal and consistent experience, CWG may exchange and combine personal information with other CWG entities for the purposes described in this Privacy Policy.

If your personal information is collected using a document that references this Privacy Policy, you are taken to consent to the disclosure, transfer, storing or processing of your personal information outside of Australia.

You acknowledge and understand that by providing such consent:

  • CWG will not be required to take steps as are reasonable in the circumstances to ensure that such third parties comply with the APPs;
  • if the overseas recipient handles your personal information in breach of the APPs:
    • CWG will not be liable under the Act; and

    • you will not be able to seek redress under Act.

  • the overseas recipient may not be subject to any privacy law or principles similar to the APPs;
  • you may be unable to seek redress overseas;
  • the overseas recipient may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

If you withdraw consent, CWG will not rely on this consent when dealing with your personal information going forward.

19.   Anonymity

You have the option of not identifying yourself or using a pseudonym when dealing with CWG provided that is it lawful and practicable.

CWG will try to accommodate a request for anonymity if possible.  However, your right to anonymity does not apply in relation to a matter if:

  • CWG is required/authorised by law or court/tribunal order to deal with identified individuals; or
  • it is impracticable for CWG to deal with individuals who have not identified themselves.

It is CWG’s policy to enable you to access CWG’ website and make general phone queries without having to identify yourself and to enable you to respond to CWG’s surveys anonymously.

In some cases however, if you don’t provide CWG with your personal information when requested, CWG may not be able to respond to your request or provide you with service. For example, you must identify yourself to become a CWG member or franchisee.

20.   Accessing to your personal information

You have the right, upon request, to access any of CWG’s records containing your personal information.

To request access to your personal information please contact the Privacy Officer.

CWG will respond to your request to access your personal information within a reasonable period of time.

On the basis that it is reasonable and practicable to do so, CWG will give you access to the information requested.

If CWG refuses your request to access personal information, CWG will provide a written notice setting out the reasons for the refusal & how you can complain about the refusal.

Reasons for a refusal may include if it:

  • poses a serious threat to the life, health or safety;
  • would have unreasonable impact on privacy of others;
  • is frivolous or vexatious;
  • relates to legal proceedings;
  • reveals CWG’s intentions or prejudices any negotiations;
  • would be unlawful;
  • is required or authorised by law or court/tribunal order;
  • is likely to prejudice enforcement related activities; or
  • relates to a commercially sensitive decision process.

When you make a request to access personal information, CWG will require you to provide some form of identification (such as a driver’s licence or passport) so CWG can verify that you are the person to whom the information relates.

21.   Help CWG keep your personal information accurate

CWG will take reasonable steps to ensure CWG’s records of personal information are accurate, up to date and complete.

However, the accuracy of information depends to a large extent on the information you provide.  If you do not give CWG all the personal information CWG may require, or the personal information provided is inaccurate or incomplete, then the products, services and information CWG provide may be affected.

If you think there is something wrong with the information CWG holds about you please contact the Privacy Officer to:

  • let CWG know if there are any errors; and
  • keep CWG up-to-date with any changes,

and CWG will try to correct your personal information.

CWG will respond to your request to correct your personal information free of charge and in a reasonable period of time.  If CWG refuses your request, CWG will provide you with a written notice setting out the reasons for the refusal and mechanisms available to complain about the refusal.

If CWG refuses to correct your personal information, you may request that CWG associate your information with a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading.  CWG will take reasonable steps to make the statement visible to users of your personal information.

If CWG does correct your personal information and CWG has previously disclosed your personal information to a third party, upon your request, CWG will notify that third party of the correction unless it is impracticable or unlawful to do so.

22.   Dealing with SPAM and Do Not Call register

CWG will not send you any commercial electronic messages unless it is permitted by the Spam Act (e.g., CWG has your express/inferred consent). Any commercial electronic message that CWG sends will identify CWG as the sender and will include relevant contact details and an unsubscribe facility.  If you do not wish to receive commercial electronic messages from CWG, please contact the Privacy Officer.

CWG will not call you on a number on the Do Not Call Register unless permitted under the Do Not Call Register Act & related instruments.  If you don’t wish CWG to call you on a particular number, please contact the Privacy Officer.

23.   Resolving your privacy issues

If you have any issues you wish to discuss with CWG or if you’re concerned about how CWG has collected or managed your personal information please contact the Privacy Officer.

For information about privacy or if your concerns are not resolved, contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.

24.   Changes and access to this privacy policy

CWG may, from time to time, review and update this privacy policy to take account of new laws and changes to CWG’s operations.  Changes to this Privacy Policy will not affect CWG’s use of previously provided information.

This Privacy Policy is available on CWG’s website at www.collectivewellness.com.au.  A printed Privacy Policy can be obtained free of charge by contacting the Privacy Officer.

25.   CWG privacy officer

CWG’s privacy officer can be contacted at:

  • Email: privacy@collectivewellness.com.au
  • Telephone: 02 9415 5360
  • Post: Level 2, 71 Longueville Road, Lane Cove NSW 2066

Privacy Collection Notice

CWG Investments Pty Ltd (ACN 612 517 781), its related entities and franchised businesses (collectively, CWG) use this collection notice to set out the prescribed information in the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth) (Act). 

1.   CWG Privacy Policy

A complete summary of CWG’s policies relating to the privacy of your personal information is available on CWG’s website at www.collectivewellness.com.au (Privacy Policy).

 The Privacy Policy explains how you may access personal information held by CWG and seek the correction of the information and how you may complain about a breach by CWG, or a registered APP code (if any) that CWG is bound by and how CWG will deal with a complaint.

A printed copy of the privacy policy can be obtained free of charge by contacting CWG’s Privacy Officer.

2.   CWG’s contact details

If you have any questions or concerns regarding CWG’s Privacy Policy or CWG’s use of your information, please contact CWG’ privacy officer at:

  • Email: privacy@collectivewellness.com.au
  • Telephone: 02 9415 5360
  • Post: Level 2, 71 Longueville Road, Lane Cove NSW 2066

3.   How CWG collects your personal information (if collected from someone other than you)

CWG may collect your personal information from third parties including:

  • market researchers & direct marketing providers;
  • parents or guardians of underage members;
  • our current members (refer a friend);
  • the Australian Tax Office (ATO) and the Australian Securities and Investment Commission (ASIC); and
  • public sources (directories, lists, professional & trade associations, ASIC, bankruptcy or court registry searches).

4.   Is the collection of your personal information required/authorised by law or a court/tribunal order?

No.

5.   Why did CWG collect the personal information?

The main purpose for which CWG collects personal information is to provide services and benefits to members and to maintain, extend and grow CWG’s membership.

CWG may use your information for:

  • processing & managing membership & franchisee applications;
  • facilitating members & casual members CWG outlet access and the provision of services;
  • marketing activities, research & special offers;
  • accurately identifying who is using CWG’ services;
  • communicating with members, franchisees & website visitors to CWG’ website & online enquiries;
  • profiling our members & their interests;
  • operating CWG’s business; and / or
  • transferring memberships and making membership services available between CWG outlets.

6.   Consequences to you if CWG does not collect all or some of your personal information

You can refuse to provide personal information. However a refusal may mean that the service you requested is not provided or membership will be refused or forfeited.

7.   Sharing your personal information

CWG may use and disclose personal information for related purposes to third parties. Types of organisations to whom CWG may disclose your personal information includes:

  • government bodies such as ATO, ASIC, Australian Prudential Regulatory Authority & police or courts (as required by law);
  • various law enforcement agencies and governments for security, customs and immigration purposes;
  • banking service providers;
  • rewards partner program providers;
  • professional or government organisations; and
  • CWG’ contracted service providers including:
    • CWG’s master franchisor;

    • information technology service providers;

    • planning research & development providers;

    • conference organisers;

    • marketing & communications agencies;

    • mailing houses, freight & courier services;

    • printers & distributors of marketing material;

    • debt collectors & banks; and

    • external advisers (recruiters, auditors & lawyers).

CWG does not rent, sell or exchange your personal information to third parties without your prior approval.

8.    Does CWG disclose your personal information overseas?

CWG and CWG group entities may disclose your personal information to other third party service providers operating outside Australia who work with CWG or one of CWG’ suppliers, agents, or partners, or its master franchisor. CWG may also store your personal information on servers based overseas or in the “cloud” or other types of networked or electronic storage.

Before disclosing your personal information to an overseas third party, CWG will first take reasonable steps to ensure that the overseas recipient:

  • does not breach the Australian Privacy Principles (APPs) in relation to your personal information; or
  • the recipient of the information is subject to a law, or binding scheme, that has the effect of protecting your personal information in a way that is substantially similar to the way in which the APPs protect the information.

Personal information may be disclosed by CWG to other CWG entities and third parties in jurisdictions including Australia, Canada and the United States of America.

To make it easy for you to deal with CWG and other CWG entities and to provide you with a more personal and consistent experience, CWG may exchange and combine personal information with other CWG entities for the purposes described in this Collection Notice.

Despite the above, if your personal information is collected using a document that references this Collection Notice, you are taken to consent to the disclosure, transfer, storing or processing of your personal information outside of Australia.

You acknowledge and understand that by providing such consent:

  • CWG won’t need to take steps as are reasonable in the circumstances to ensure such third parties comply with APPs;
  • if the overseas recipient handles your personal information in breach of the APPs, CWG will not be liable under the Act and you will not be able to seek redress under Act.
  • the overseas recipient may not be subject to any privacy law or principles similar to the APPs;
  • you may be unable to seek redress overseas;
  • the overseas recipient may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

If you withdraw consent, CWG will not rely on this consent when dealing with your personal information going forward.