This document describes the privacy policy of Päivi Hänninen (Paeivi Haenninen), trading as WMNS TRI (ABN 65321250566) (“WMNS TRI”, “we”, “us”) for protecting the privacy of personal information we collect about you, including through our website and/or services or directly from you.

 ​

1. The Personal Information We Collect 

 

The types of personal information we collect may include: 

• Name, date of birth, address(es), contact numbers, email address and other contact details; 

• Demographic data such as age and location; 

• Transaction data (including details about payments to and from you and other details of products you have purchased from us);

• Technical data (including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website); 

• Profile data (including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses);

• Usage data (including information about how you use our website, products, and services); and 

• Marketing and communications data (including your preferences in receiving marketing from us and our third parties and your communication preferences).

 

We may collect the above types of personal information from people including website visitors, email subscribers, social media followers, employment applicants, potential clients, and service providers.

 

2. Sensitive Information 

We may also collect the following sensitive information: 

• Health information, including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors; and

• Details of health service providers involved in your care (e.g. referring doctor's/physiotherapist’s/osteopath’s name, phone and address), and copies of any referral letters and/or medical reports and test results (e.g. pathology results, imaging reports) 

 

We collect sensitive information from clients we are providing services to when we see that information to be important for us to provide safe and correctly individualised services, or potential clients who have requested our services. 

 

3. How we collect information
 

We are committed to using lawful and fair means to collect personal information and collecting it from others only when it is unreasonable or impracticable to obtain certain information from our clients directly.

 

We may collect personal information from someone in several ways:

• visits our website;

• makes an enquiry with us (for example, by telephone or email);

• purchases a product or service from us; 

• signs up to a marketing subscription, such as a newsletter sign-up form; 

• contacts us via email, our website or via social media such as Facebook or Instagram;

• completes a new client sign-up form; and

• participates in one of our programs or services.

​

We collect sensitive information in more limited circumstances, such as:

- makes an enquiry with us and the sensitive information is disclosed to us to facilitate referral to an appropriate service provider 

- participates in one of our programs or services and the sensitive information is disclosed to us to facilitate the delivery of the program or service 

 

4. How We Hold and Protect Personal Information
 

We store all personal information we collect electronically, including on or within: 

• Dedicated information storage software, such as client relationship management (CRM) software;

• The backend of our website; and

• The backend of our social media accounts, such as Facebook and Instagram 

 

5. Security
 

We are committed to ensuring that the personal information we hold is secure and protected from misuse, interference, loss and unauthorised access, modification or disclosure. We undertake the following precautions to protect personal information we hold:

• our website contains pages encrypted with SSL (Secure Sockets Layer) to ensure the safety of any data that is submitted through use of this website; 

• we limit access to personal information to a “need-to-know” basis; 

• the backend of our website and social media accounts is password protected; 

• we protect devices we use to collect, hold, use and disclose personal information with industry-standard anti-virus software;

• our devices are protected by passwords and are stored in secure premises;

• data is securely stored on cloud servers;

• all conversations involving the discussion of personal information take place in private, where conversations are unable to be overheard by unauthorised personnel; and 

• if we no longer need personal information, we take reasonable steps to delete or deidentify the information.

 

We take extra precautions to protect sensitive information, including: 

• all sensitive information is held in secure storage systems protected by passwords;

• we protect devices we use to collect, hold, use and disclose sensitive information with industry-standard anti-virus software;

• our devices are protected by passwords and are stored in secure premises;

• data is securely stored on cloud servers;

• all hard copies of sensitive information are kept in secure storage with access by authorised personnel only; and

• all conversations involving the discussion of sensitive information take place in private, where conversations are unable to be overheard by unauthorised personnel. 

 

If a data breach occurs involving personal information and the breach is likely to cause harm, we will notify the individual as soon as possible after the occurrence in accordance with our obligations under the Privacy Act and related legislation.

 

6. Why We Collect, Hold, Use and Disclose Personal Information

 

We collect, hold, use and disclose personal information as is reasonably necessary for us to operate our business and provide our services, including for the following purposes: 

• to contact and communicate with clients and potential clients; 

• to deliver digital and physical products;

• to ensure we are providing the right service for clients;

• to ensure the accurate and safe provision of services;

• to communicate with other healthcare providers involved in a person’s care; 

• to conduct activities relating to research, quality assurance and improvement processes, accreditation, audits, risk and claims management, client satisfaction surveys and staff education and training;

• to market to you and others, including remarketing; 

• for statistical purposes; and

• as required by law.

 

We only collect, hold, use and disclose sensitive information where it is necessary for us to provide a service we have been engaged to perform, and not for any unrelated purposes (for example, for research or marketing), unless we have received the person’s prior informed consent. We do not disclose personal information to overseas recipients. We never sell or rent personal or sensitive information we collect. 

 

7. Requests to Access, Correct or Delete Information 

 

Access: 

You can request details of personal information that we hold about you in certain circumstances set out in the Privacy Act 1988 (Cth) (the Act). We may refuse to provide you with information that we hold in certain circumstances set out in the Act. Otherwise, we will provide access to the information if it is reasonable and practicable to do so. In most cases we will do this free of charge, but if your request requires significant effort or expense on our part, we might ask for compensation for that. 

 

Correction: 

If you believe that any information, we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details set out below. We will endeavour to promptly correct any information found to be inaccurate, incomplete, or out of date and to notify of the correction, unless it is impracticable or unlawful to do so.

 

Deletion:

If you want us to delete personal information, we hold about you or to not collect information from you for a specific purpose, please contact us using the details set out below. Please note that if we agree to delete information, because of backups and records of deletions, it may be impossible to completely delete the information without retaining some residual information. We will respond to any request to access, correct, or delete information within a reasonable time. 

 

Unsubscribe:

 We like to keep our customers and website visitors up to date, so from time to time we will send you newsletters, invitations, and updates. You can always "Unsubscribe”, meaning that you can opt out at any time. To unsubscribe from our email database, or opt out of communications, use the “Unsubscribe” button in our communication or contact us using the details set out below.

​

8. Client information under EU law

 

WMNS TRI is committed to looking after our customers in the EU and we make every effort to comply with the European General Data Protection Regulation (GDPR), including by processing your personal data in accordance with the principles of data processing set out in the GDPR. 

 

Your rights 

 

You have the following rights under the GDPR:

• the right of access (the right to access personal information we process); 

• the right of rectification (the right to require us to rectify inaccurate personal information or complete our records); 

• the right to be forgotten (the right to require us to erase all your personal information in certain circumstances); 

• the right to restriction of processing (the right to restrict how or why we process your personal information); 

• the right to data portability (the right to receive a copy of your personal information); 

• the right to object (the right to object to us processing your personal information); and 

• the right of review (the right to request a human review of automated decision making or profiling). 

 

You can exercise any of these rights by emailing us at hello@wmnstri.com.

​

9. WMNS TRI’s Commitment

​

The personal data we collect is: 

• processed lawfully, fairly and transparently;

• collected for the specified, explicit and legitimate purposes including creating our mailing list, direct marketing, taking payments and delivering goods or services to you;

• adequate, relevant and limited to what is necessary for our purposes; 

• accurate, and where necessary, kept up to date (we will take every reasonable step to ensure that inaccurate personal data is erased or rectified without delay);

• not stored than for longer than is necessary; and

• processed in a manner that ensures appropriate security of the personal data. 

 

10. Your Consent

 

When you visit our website, purchase any services/products or interact with us in social media you are accepting this privacy policy and giving us consent to process your personal data. You can withdraw that consent at any time by sending an email to hello@wmnstri.com. If you ask us to, we will stop using your personal data as soon as possible.

 

 

If you have any questions about your privacy with WMNS TRI, please contact us at hello@wmnstri.com or contact us here >>.

 

​

Last edited 2023. Päivi Hänninen. WMNS TRI.