Welcome to the Springday health and wellbeing technology platform.
At Springday, your privacy and the security of your personal information is a major priority for us. We want our visitors to feel protected when visiting and using the Springday health and wellbeing technology platform and our Programs, Tools and Online Community (collectively “the Platform”), which are available at url: Springday.com.au and at any other website which we operate on behalf of our corporate partners (“Website”) (collectively the “Springday Services”).
1. What information does Springday collect?
- Personally Identifiable Information
- Non-Personally Identifiable Information
- from users of the Platform – for example:
– your name, email address, birth date, phone number, gender and location when you create your Profile;
– details of, for example, your lifestyle, health, fitness and recreational activities and associated goals;
– details of any steps you have taken via the Platform, for example, participation in a health or fitness challenge, booking a flu vaccination etc.
- from our corporate clients and suppliers – for example, full names of key contacts, employer name, work contact details (including address, phone number, fax number and email address).
- from job applicants and employees – for example, full name, contact details (including address, phone number and email address), driver’s licence details, job title, passport details, employment history and education details, names and contact details of referees, next of kin details (in the event of an emergency) and superannuation fund and Tax File Number details, if required by law, for example, under the Superannuation Guarantee (Administration) Act, the Superannuation Industry (Supervision) Act, the Income Tax Assessment Acts and Taxation Administration Act.
- wearables and connected fitness devices and platforms, such as Fitbit and Garmin;
- consumer health applications; and
- health data aggregators, such as Apple Health,
2. How does Springday collect PII?
- join the Platform and create and manage your profile;
- use the Wellbeing Check Tool, which is available on the Platform;
- choose customised content, Programs, Tools and incentives, including when you connect wearables and connected fitness devices and platforms (such as Fitbit and Garmin), consumer health applications and/or health data aggregators (such as Apple Health) with particular Programs and Tools on the Platform;
- subscribe to receive our newsletter or promotional materials or sign up to a mailing list;
- participate in challenges on the Platform or enter competitions, surveys or other promotional activities available on the Platform or Website; and
- interact with us by phone, email, mail, or via the Website, a Platform or any of our social media pages if, for example, you are a user of the Platform or a corporate client key contact.
We may also collect your PII from third parties. This may include (but is not limited to) the collection of your PPI from:
- your employer, for example, if your employer has engaged us to provide the Platform and Springday Services to its employees;
- nursing service providers, for example, if your employer has engaged a nurse to assist with the completion of your well-being assessment;
- someone duly authorised to act on your behalf;
- where you have provided consent, from your private health insurer and/or medical or health practitioner to, for example, co-ordinate any care requirements you may have; and
- recruiters we have retained, from referees you have provided in support of a job application and any service provider we may engage to conduct background checks on job applicants.
As stated above, Springday may also access data from your wearables and connected fitness devices, consumer health applications and/or health data aggregators if you chose to use them in connection with a Program or Tool available on the Platform.
Data permissions for Personal Data access
Registration and authentication provided directly by this Application
3. How does Springday collect NPII?
4. How does Springday use the information we collect?
- assist you to monitor and improve your health, fitness and wellbeing. For example, if you have completed the Wellbeing Check Tool, we will use your PII to send you an overview on your wellbeing based on your responses when completing the Wellbeing Check;
- send you details of, for example, Programs, Tools and service providers etc which may assist you with your health, fitness and wellbeing;
- manage appointments you may schedule via the Platform;
- send you direct marketing messages which we consider may be of interest to you;
- the prevention of fraud and/or identifying and investigating any suspicious use of our Website, Platform or the Springday Services;
- for our internal business and management processes, for example accounting or auditing purposes;
- for any other purpose to allow us to comply with our obligations under law; and
- for any other purposes that would reasonably be expected by you.
- changing your account settings by logging into your profile on the Platform or Website;
- following the unsubscribe instructions in any marketing communications we may send to you; or
- contacting us using the contact details below and informing us that you wish to opt-out.
- help us understand who uses our Website and Platform, how they are used and to improve our Tools, Programs and the Online Community.
- perform statistical analysis of user behaviour, to analyse and evaluate issues relating to nutrition, weight loss, behaviour and fitness, and/or to evaluate and improve the Springday Services and Platform. We may link some of this information to PII for internal purposes only or to assist you in achieving your health and wellness goals.
Mode and place of processing the Data
- Users have given their consent for one or more specific purposes. Note: Under some legislations Springday may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which Springday is subject
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Springday
- processing is necessary for the purposes of the legitimate interests pursued by SPringday or by a third party.
In any case, Springday will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at Springday’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Springday to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with Springday using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of Springday’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Springday within the relevant sections of this document or by contacting Springday.
Springday may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Springday may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
5. Does Springday disclose information to third parties?
6. Third Party Websites
7. How does Springday secure the information we collect?
8. Can you access, update or correct your PII?
9. Who do I contact if I have a privacy question or wish to lodge a complaint?
Last Updated: 18 February 2022
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).