Fitness & Lifestyle Group Privacy Policy

FITNESS & LIFESTYLE GROUP’S COMMITMENT TO PRIVACY

Fitness & Lifestyle Group Topco Pty Ltd (*ACN 614 113 192), its subsidiaries and affiliates in Australia (collectively referred to as (“*Fitness & Lifestyle Group”) are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth), and in accordance with other applicable privacy laws.

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, "we", "us" and “our” refers to Fitness & Lifestyle Group and "you" refers to any individual about whom we collect personal information.

This Privacy Policy applies to all personal information collected by us, or submitted to us, whether offline or online, including personal information collected or submitted through any of our websites, through our official social media channel pages which we control (such as our LinkedIn page), as well as through email messages that we send to you.

ABOUT FITNESS & LIFESTYLE GROUP

Fitness & Lifestyle Group is the parent company for a portfolio of fitness brands that consist of multiple gym locations in South East Asia including Australia and New Zealand as well as online fitness and wellness offerings.

Fitness & Lifestyle Group’s portfolio of brands offer a range of services, including fitness centres, personal training and group training, online workout and nutrition tutorials.

WHAT INFORMATION DOES FITNESS & LIFESTYLE GROUP COLLECT ABOUT YOU?

Members and prospective members

If you enquire about the services of any of Fitness & Lifestyle Group’s portfolio of brands, access any of their websites or when you become a member of any of Fitness & Lifestyle Group’s gyms that fall within its portfolio of brands you will be subject to the terms and conditions of the Privacy Statement relevant for that fitness organisation.

Prospective employees/applicants

We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.

We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions.

We may also collect relevant information from third party sources such as LinkedIn and other professional websites.

Other individuals

Fitness & Lifestyle Group may collect personal information about other individuals. This includes members of the public who interact with Fitness & Lifestyle Group on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Fitness & Lifestyle Group. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.

You can always decline to give Fitness & Lifestyle Group any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.

Visitors to our websites

The way in which we handle the personal information of visitors to our websites is discussed below.

What happens if you don’t provide your personal information?

You can always decline to give Fitness & Lifestyle Group any personal information we request, but that may mean we may not be able to do business with you effectively. If you have any concerns about personal information we have requested, please let us know.

HOW AND WHY DOES FITNESS & LIFESTYLE GROUP COLLECT AND USE YOUR PERSONAL INFORMATION?

Fitness & Lifestyle Group collects personal information reasonably necessary to carry out our business, and provide our services to you.

The purposes for which Fitness & Lifestyle Group usually collects and uses personal information depends on the nature of your interaction with us, but may include:

responding to requests for information and other general inquiries;

informing you of our activities, events, facilities and services;

recruitment processes; and

responding to enquires and complaints.

In addition, some of your personal information may be used for other business purposes. Examples of the types of uses are set out below:

to confirm your identity and carry out background checks, including as part of our checks in relation to your application to work with us;

to comply with any requirement of any applicable statute, regulation, rule and/or good practice, whether originating from Australia or elsewhere;

to prevent or detect abuse of our services or any of our rights (and attempts to do so), and to enforce or apply our Privacy Policy and/or any other agreement and to protect our (or others') property or rights;

if instructed to do so by you or where you give us your consent to the use and/or processing involved;

to bring to your attention (in person or by post, email or telephone) information about additional services offered by us and/or our global affiliate, which may be of interest to you, unless you indicate at any time that you do not wish us to do so; and

Fitness & Lifestyle Group generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person.

In some cases it will be lawful for us to collect and use your personal information, for example where it is necessary as part of our, or a third party’s, statutory or public functions or because the law permits or requires us to.

HOW DOES FITNESS & LIFESTYLE GROUP INTERACT WITH YOU VIA THE INTERNET?

You may visit our websites without identifying yourself. ** If you identify yourself (for example, by providing your contact details in your dealings with us), any personal information you provide to Fitness & Lifestyle Group will be managed in accordance with this Privacy Policy.

Fitness & Lifestyle Group's website may contain links to third-party websites. Fitness & Lifestyle Group is not responsible for the content or privacy practices of websites that are linked to our website.

CAN YOU DEAL WITH FITNESS & LIFESTYLE GROUP ANONYMOUSLY?

Fitness & Lifestyle Group will provide you with the opportunity of remaining anonymous or using a pseudonym in your dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally it is not practicable for Fitness & Lifestyle Group to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

HOW DOES FITNESS & LIFESTYLE GROUP HOLD INFORMATION?

Fitness & Lifestyle Group stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

Fitness & Lifestyle Group maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

Our website do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our website are encouraged to exercise care in sending personal information via the internet.

HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT BY FITNESS & LIFESTYLE GROUP

We will only keep the personal information we collect about you for as long as is necessary for the purposes set out in this Privacy Policy or as required to comply with any legal obligations to which we are subject. The retention periods we apply take account of:

legal and regulatory requirements and guidance;

limitation periods that apply in respect of taking legal action;

our ability to defend ourselves against legal claims and complaints;

good practice; and

the operational requirements of our business.

We take steps to destroy or de-identify information that we no longer require or as required by an applicable law.

DOES FITNESS & LIFESTYLE GROUP USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?

Fitness & Lifestyle Group may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you or as otherwise permitted under applicable privacy laws.

This means under certain privacy laws we do not always need your consent to send you marketing communications such as our member newsletter. However, where consent is required under applicable privacy laws, we will ask for this consent separately and clearly. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below or using the opt-out functionality contained in the electronic message.

If you opt-out of receiving marketing material from us, Fitness & Lifestyle Group may still contact you in relation to its ongoing relationship with you.

HOW DOES FITNESS & LIFESTYLE GROUP USE AND DISCLOSE PERSONAL INFORMATION?

Use and disclosure for administration and management

Fitness & Lifestyle Group will also use and disclose personal information for a range of administrative, management and operational purposes. This includes responding to enquiries and complaints regarding our services;

Other uses and disclosures

We may use and disclose your personal information for other purposes explained at the time of collection (such as in a specific privacy collection statement or notice) or otherwise as set out in this Privacy Policy.

DOES FITNESS & LIFESTYLE GROUP DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?

Fitness & Lifestyle Group is a global organisation and works with members, service providers, sponsors and commercial interests across the globe It is likely that your personal information will be disclosed to overseas recipients including service providers who may handle, process or store your personal information on our behalf.

The recipients of such information may be located in Singapore, Thailand, Indonesia, Vietnam, Hong Kong, Philippines.

Entities which are related entities of Fitness & Lifestyle Group, or are otherwise affiliated with Fitness & Lifestyle Group, have operations in Singapore, Thailand, Indonesia, Vietnam, Hong Kong, Philippines.

We generally collect personal information about you in Australia or the jurisdiction in which the Fitness & Lifestyle Group affiliate you are dealing with is located.

It is likely that your personal information will be transferred outside of the jurisdiction it was collected. We only ever disclose your personal information outside the jurisdiction it was collected where we are permitted to do so under applicable privacy laws. Generally this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws.

There are circumstances where we may disclose your personal information to an overseas recipient. You have provided your consent or we are otherwise permitted to do so under the Australian Privacy Principles or other relevant laws.

HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?

You are entitled to access your personal information held by Fitness & Lifestyle Group on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?

You may contact Fitness & Lifestyle Group at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that Fitness & Lifestyle Group 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 www.oaic.gov.au.

HOW CHANGES ARE MADE TO THIS PRIVACY POLICY?

Fitness & Lifestyle Group may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes. We also try to let you know about major changes to our Privacy Policy (for example by putting a notice up on our website).

HOW CAN YOU CONTACT FITNESS & LIFESTYLE GROUP?

The contact details for Fitness & Lifestyle Group are:

Fitness & Lifestyle Group Privacy Officer: [email protected]

This Privacy Policy was last updated in September 2018.

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