Website Privacy Policy
Last Updated on May 27th, 2019
Introduction

 Hi there! The following websites are owned and operated by Geraldine Headley, trading as “Highgate Proactive Health” and “Mentoring with Geraldine” ABN: 66586022324:

• https://proactivhealth.com.au
• https://mentoringwithgeraldine.com, and
• https://mentoring-with-geraldine.teachable.com/

If you have any questions or need further information, please contact Geraldine:
Clinic Address: 25 Yeo Avenue, Highgate, South Australia 5063
Email: geraldinehealth@gmail.com
Phone: 0410148503

This document sets out my Privacy Policy. It describes how I collect and manage your personal information when you interact with this site, undertake training or mentoring with me, or become my client. I take this responsibility very seriously. If you have any questions or concerns about how your personal information is being handled, please do not hesitate to contact me.
I comply with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
I understand that visitors from the EU may access this site, so I also aim to comply with the General Data Protection Regulations (GDPR).

Personal Information

 If you engage with me via this website, or choose to work with me, I may ask to collect the following kinds of personal information from you, including:
• your name and email address when you opt into my email,
• information about your interests & preferences, such as your opinion about future topics, products or services that may interest you,
• information that allows me to tailor my content to your needs when you sign up for one of my webinars or promotional events, or otherwise interact with me, and
• basic information about your interaction with my website.

Collection and Use

 I may collect your personal information by various means including:
• through the contact form on my website,
• when you email me,
• when you subscribe to my newsletter,
• when you opt-in to receive a free resource,
• when you sign up to attend a seminar, webinar or event,
• in person at a seminar, webinar or event,
• when I request a testimonial after we have worked together,
• when you become my client or purchase from me,
• information automatically collected by my website such an analytics and cookies,
• if you are referred to me, or
• if you are working with me as a mentor.

I use this information to:

• respond to your enquiries,
• provide you with the services that you have requested,
• monitor your satisfaction with my website & my services,
• help other people to understand my services better,
• improve my products and services,
• provide you with more relevant information,
• provide you with relevant news and updates about my services, and
• provide news about developments in my areas of work.

I will only collect your personal information:

• with your full awareness and consent, such as when you email me, tick a checkbox or fill in a form to provide me with information,
• if I need it to provide you with information or services that you request,
• if I am legally required to collect it,
• for necessary administrative processes if you become my client, or
• if I believe that I can demonstrate a legitimate interest in using your data for marketing purposes, although I will always give you a choice to opt out.

Sensitive Information

I understand that some personal information is particularly sensitive.
I will only collect sensitive information by methods that are reasonably secure, such as:
• through my intake form in Acuity when you book an appointment,
• in a consultation, whether via Zoom or in person, and
• when you send me information in an email.

The reason why I collect this information is:

• so that I can provide you with the services you have contracted for, and
• to ensure that I am providing you with the most appropriate services.
The sensitive information I ask you to provide for this purpose may include:
• your date of birth and age,
• information about your health and medical history,
• your family medical history,
• your personal and sexual health, and
• your current symptoms,
I am committed to securely storing and handling your sensitive information.

Sensitive information is stored

• in Acuity if submitted through an intake form,
• in a password protected GSuite account,
• as handwritten notes in a locked filing cabinet, and
• on a password protected computer in a locked room.

Only I have access to sensitive material shared by my clients and those I mentor. Limited access may be provided to my VA or a team member, but only on a strictly need-to-know basis.

As mentioned above, some sensitive information may be stored securely online, or in the cloud through Acuity and GSuite. Deidentified information may also be stored on Teachable. You can find out more about their security provisions here:

• Acuity:
https://help.acuityscheduling.com/hc/en-us/articles/219149587-Security-Privacy-Compliance

• GSuite:
https://gsuite.google.com/security/?secure-by-design_activeEl=data-centers

• Teachable:
https://support.teachable.com/hc/en-us/sections/360000227471-User-Security

Sensitive information may be collected from children under the age of 18 but only with their parent or guardian’s full consent. All information collected from minors is securely stored in accordance with this privacy policy.
All archived sensitive information is securely destroyed after 7 years. Paper notes are shredded and mulched.

Professional Considerations

 As a naturopath, I owe a duty of care and confidentiality to my clients, and I take this duty very seriously.
You may choose not to provide me with your personal information. However, if you choose not to be completely honest with me, it can cause problems. I may not be able to provide you with the services that you request, and any treatment I provide may be ineffective or have unintended consequences. As a result, I ask that you always provide me with accurate information.

Use of Personal Information

I will use all reasonable means to protect the confidentiality of your personal information while in my possession or control. I will not knowingly share any of your personal information with any third party other than the service providers who assist me in providing the information and/or services I am providing to you. To the extent that I do share your personal information with a service provider, I would only do so if that party has agreed to comply with our privacy standards as described in this privacy policy. However, some of my service providers may be overseas and may not be subject to Australian Privacy Laws or compliant with GDPR. Please contact me if you have any concerns about the potential disclosure of your information.

Reasons why I may disclose your personal information include:

• where disclosure is necessary to provide you with the information or services you have requested, or
• where the administration of my business requires disclosure to my VA or support services.
In order to do this, I may share some relevant personal information - on a strictly need to know basis - with:
• my email marketing provider,
• my virtual assistant (VA) and similar independent contractors,
• my accounting and legal team,
• my business consultant or coach,
• my website and technology team, and
• my CRM provider.

I will also disclose your information if required by law to do so or in circumstances permitted by the Privacy Act – for example, where I have reasonable grounds to suspect that unlawful activity, or misconduct of a serious nature, that relates to my functions or activities has been, is being or may be engaged in, and in response to a subpoena, discovery request or a court order.

If you have any concerns regarding the disclosure of your personal information, please do not hesitate to get in touch with me to discuss this personally.

Security

I take reasonable physical, technical and administrative safeguards to protect your personal information from misuse, interference, loss, and unauthorised access, modification and disclosure.

I manage risks to your personal information by:

• storing files securely,
• ensuring that only I have access to sensitive information,
• releasing information to service providers on a strictly need-to-know basis, and
• conducting regular audits of my security systems.

As mentioned above, your personal information may also be stored with a third-party provider, where it will be managed under their security policy. I have provided links to the appropriate policies. If you have any concerns, please contact the provider directly or let me know.

Access to Information

You can contact me to access, correct or update your personal information at any time. Unless I am subject to a confidentiality obligation or some other restriction on giving access to the information which permits me to refuse you access under the Privacy Act, and I believe there is a valid reason for doing so, I will endeavour to make your information available you within 30 days.

Please begin the process by sending an email requesting access to your information to me at geraldinehealth@gmail.com and I will endeavour to respond within 7 days].

Complaints

If a breach of this Privacy Policy occurs, or if you wish to a request a change to your personal information, you may contact me by sending an email outlining your concerns to me at geraldinehealth@gmail.com and I will endeavour to respond within 48 hours.

If you are not satisfied with my response to your complaint you may seek a review by contacting:

• Naturopaths & Herbalists Association of Australia, using the information available at https://www.nhaa.org.au/public/feedback-complaints, or

• the Office of the Australian Information Commissioner using the information available at http://www.oaic.gov.au/privacy/privacy-complaints.

Notification of Change

When I update my Privacy Policy, I will post a copy of the revised policy on my website.

Notification of Breach

If I have reason to suspect that a serious data breach has occurred and that this may result in harm or loss to you, I will immediately assess the situation and take appropriate remedial action. If I still believe that you are at risk, I will notify the Office of the Information Commissioner and either notify you directly, or if that is not possible, publicise a notification of the breach on this website.

PRIVACY POLICY AND COOKIE POLICY
INTRODUCTION
If you are visiting this page you may have been directed from one of our group of websites. We have created this privacy statement in order to demonstrate our firm and continuing commitment to the privacy of personal information provided by those visiting and interacting with any website controlled by Geraldine Headley. We hold the privacy of your personal information in the highest regard. The following discloses our information gathering and dissemination practices for these websites. Geraldine Headley abides by the rules dictated in law by the U.S. FCC (Federal Communications Commission).

We recognize the importance of protecting your privacy and our policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions when using our sites. This policy will be continuously assessed against new technologies, business practices and our customers’ needs.

WHAT INFORMATION DO WE COLLECT?

When you visit these websites you may provide us with two types of information: personal information you knowingly choose to disclose that is collected on an individual basis and Web site use information collected on an aggregate basis as you and others browse our Web site.

1. PERSONAL INFORMATION YOU CHOOSE TO PROVIDE

REGISTRATION INFORMATION

When you register for any of our products, services or newsletters you will provide us information about yourself.
Credit Card Information
If you choose to avail of our services, you may need to give personal information and authorization to obtain information from various credit services. For example, you may need to provide the following information:

Name
Mailing address
Email address
Credit card number
Name on credit card
Credit card billing address
Business and home phone number
Email Information
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.

2. WEB SITE USE OF INFORMATION

Similar to other commercial Web sites, our Web sites utilize a standard technology called “cookies” (see explanation below, “What Are Cookies?”) and web server log files to collect information about how our Web site is used. Information gathered through cookies and Web server logs may include the date and time of visits, the pages viewed, time spent at our Web site, and the Web sites visited just before and just after our Web site.

HOW DO WE USE THE INFORMATION THAT YOU PROVIDE TO US?

Broadly speaking, we use personal information for purposes of administering our business activities, providing the products and services you requested, to process your payment, , to monitor the use of the service, our marketing and promotional efforts and improve our content and service offerings, and customize our site’s content, layout, services and for other lawful purposes. These uses improve our site and better tailor it to meet your needs.

Furthermore, such information may be shared with others on an aggregate basis. Personally identifiable information or business information will not be shared with parties except as required by law.
Occasionally, we may also use the information we collect to notify you about important changes to our Website, new services, and special offers we think you will find valuable. You may notify us at any time if you do not wish to receive these offers by emailing us at the link provided on the newsletter.

WHAT ARE COOKIES?

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a Web site, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each Web site can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a Web site to access the cookies it has already sent to you, not the cookies sent to you by other sites. Browsers are usually set to accept cookies. However, if you would prefer not to receive cookies, you may alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, it is possible that some areas of our site will not function as effectively when viewed by the users. A cookie cannot retrieve any other data from your hard drive or pass on computer viruses.

HOW DO WE USE INFORMATION WE COLLECT FROM COOKIES?

As you visit and browse our Web site, the site uses cookies to differentiate you from other users. In some cases, we also use cookies to prevent you from having to log in more than is necessary for security. Cookies, in conjunction with our Web server’s log files, allow us to calculate the aggregate number of people visiting our Web site and which parts of the site are most popular. This helps us gather feedback to constantly improve our Web site and better serve our clients. Cookies do not allow us to gather any personal information about you and we do not intentionally store any personal information that your browser provided to us in your cookies.

The main cookies we use are: Facebook pixel, (for marketing retargeting purposes on Facebook and Instagram), Analytics by Google, (to keep track of the most visited pages to improve the experience), and “privacy_embeds” by Avada WordPress theme to store user consent to load the different third party embeds and tracking scripts.

IP ADDRESSES

IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as traffic data so that data (such as the Web pages you request) can be sent to you.

SHARING AND SELLING INFORMATION

We do not share, sell, lend or lease any of the information that uniquely identify a subscriber (such as email addresses or personal details) with anyone except to the extent it is necessary to process transactions or provide services that you have requested.

HOW CAN YOU ACCESS AND CORRECT YOUR INFORMATION?

You may request access to all your personally identifiable information that we collect online and maintain in our database by emailing us at the usual address.

WHAT ABOUT LEGALLY COMPELLED DISCLOSURE OF INFORMATION?

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights. We may also disclose account information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Service or to protect the safety of our users and the Public.

WHAT ABOUT THE OTHER WEBSITES LINKED TO OUR WEBSITE?

We are not responsible for the practices employed by Web sites linked to or from our Web site or the information or content contained therein. Often links to other Web sites are provided solely as pointers to information on topics that may be useful to the users of our Web site.
Please remember that when you use a link to go from our Website to another web site, our Privacy Policy is no longer in effect. Your browsing and interaction on any other web site, including web sites, which have a link on our Website, is subject to that Web site’s own rules and policies. Please read over those rules and policies before proceeding.

YOUR CONSENT

By using our Web site you consent to our collection and use of your personal information as described in this Privacy Policy. We reserve the right to amend this privacy policy at any time with or without notice.

OUR COMMITMENT TO DATA SECURITY:

Please note that your information will be stored and processed on our computers in Australia. The laws on holding personal data in Australia may be less stringent than the laws of your Country of residence or citizenship. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

CHOICE / OPT-IN / OPT-OUT:

This site allows visitors to unsubscribe so that they will not receive future messages. After unsubscribing we will discontinue sending the particular messages as soon as technically feasible.

SURVEYS AND CONTESTS

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.

A SPECIAL NOTE ABOUT CHILDREN

Children are not eligible to use our services unsupervised and we ask that children (under the age of 18) do not submit any personal information to us. If you are a minor, you can use this service only in conjunction with permission and guidance from your parents or guardians.

ACQUISITION OR CHANGES IN OWNERSHIP

In the event that the web site (or a substantial portion of its assets) is acquired, your information would be considered part of those assets, and may be part of those assets that are transferred.

POLICY MODIFICATIONS

We may change this Privacy Policy from time to time. If/when changes are made to this privacy policy, we will email users who have given us permission to do so. We will post any changes here, so be sure to check back periodically. However, please be assured that if the Privacy Policy changes in the future, we will not use the personal information you have submitted to us under this Privacy Policy in a manner that is materially inconsistent with this Privacy Policy, without your prior consent.
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