Hinna Pty Ltd (ABN 52 660 288 595) trading as Heelr (Heelr) provides an at-home program to assist in delivering heel and arch pain relief (Program).

Heelr recognises the importance of your privacy. This Privacy Policy explains how Heelr manages the personal information that we collect, store, use and disclose and how to contact us if you have any further queries about our management of your or your child's personal information.

We are required to ensure that all personal information pertaining to Program participants and any other individuals in relation to whom we collect personal information is treated in accordance with the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy applies to you only to the extent that the collection and handling of personal information by Heelr is subject to the Privacy Act.

Background

Where the collection or handling of your personal information by Heelr is subject to the Privacy Act, Heelr must comply with the requirements of the Privacy Act. The Privacy Act regulates the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal.

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.  

Special provisions apply to the collection of personal information which is sensitive information. This includes health information and information about a person's race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.

In this Privacy Policy, all references to personal information include sensitive information unless indicated otherwise.

What personal information does Heelr collect?

In the course of our business, Heelr may collect personal information about you and/or your child that is necessary for us to perform our functions and activities. Heelr will only collect personal information about you and/or your child by lawful and fair means and not in an unreasonably intrusive manner. 

What type of personal information do we collect?

The types of personal information we may collect and hold may vary depending on the nature of our interaction with you and/or your child and may include:

· identifying and contact information (such as name, postal address, email address and telephone phone number);

· your or your child's shoe size;

· health information to the extent that you accept that you or your child meet the Program eligibility criteria when you accept our Terms of Service; and

· credit card and payment details.

Who do we collect personal information from?

Heelr may collect personal information about a range of individuals including:

· individuals who purchase our goods and services (including the Program);

· your child if your child is a Program participant;

· visitors to our website; and

· third parties providing a product or service to Heelr, including personnel of those third parties.

How does Heelr collect personal information?

Depending on the nature of your interaction with Heelr, we may collect your and/or your child's personal information either through our website or directly from you.

For what purposes does Heelr collect, hold, use and disclose your personal information?

Heelr collects, holds, uses and discloses personal information for a range of purposes including the following:

· to provide you and/or your child with access to goods purchased and/or services rendered (including the Program);

· to process any fees payable in relation to any of the goods purchased and/or services rendered (including the Program);

· to provide you and/or your child with information about common heel and arch pain conditions;

 · to manage our relationship with you and/or your child;

· to verify and update personal information held by us;

· to engage third party service providers;

· to review, develop and continue to improve our goods and services (including the Program) including by asking individuals to participate in quality improvement surveys and activities;

· to assist with administration, planning, financial or management purposes;

· to market our services (including the running of competitions and promotions);

· to comply with legal or regulatory obligations; and

· for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.

Our range of services and our functions and activities may change from time to time.

If you provide your email address, telephone and/or mobile phone number, you also consent to Heelr using your email address, telephone and/or mobile phone number to contact you (including by telephone call, SMS or email) for any of the above purposes.

To whom may Heelr disclose your personal information?

In order to carry out the above purposes, Heelr may disclose personal information to other persons or organisations including to:

· persons or organisations engaged by Heelr to assist Heelr in carrying out the above purposes such as mailhouses, data storage providers, web platform providers, IT support providers, marketing agencies, payment platform providers, auditors, insurers and professional advisors; and

· where applicable, a third party who funds, all or in part, your or your child's access to our goods and services (including the Program) such as private health insurers and government organisations and agencies; and

 · third parties where we are legally required or authorised to do so.

What happens if you don't provide Heelr with personal information about you and/or your child?

If you do not provide personal information about you or your child to Heelr as requested, we may be unable to provide you and/or your child with the goods or services requested or otherwise work or transact with you and/or your child. 

How does Heelr hold personal information and manage the data quality and security of personal information?

Heelr uses a cloud service to store personal information in electronic form in the USA. To the extent required by the Privacy Act, Heelr will take reasonable steps to:

· make sure that the personal information that we collect, hold, use and disclose is accurate, complete and up to date; and

· protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.

Subject to the requirements of the Privacy Act, Heelr will take reasonable steps to ensure that personal information that is held which is no longer required, including under any contractual or legal requirement, is destroyed or de-identified in a secure manner. 

Does Heelr transfer personal information outside of Australia?

Heelr may disclose personal information to its overseas service providers including in the USA.

Communications

Heelr may use your personal information to contact you (including by telephone call, SMS, email or mail) in relation to products, services or other offers we think may be of interest to you and/or your child. This may include products, services or other offers of Heelr.

You may opt-out of receiving marketing information from Heelr at any time by contacting us using the contact details which appear immediately below under the heading "How can you access or correct your personal information and contact Heelr?".

Please note that if you opt-out of receiving marketing information from Heelr, we may still contact you (including by SMS and email) to provide you with information as part of the Program.

How can you access or correct your personal information and contact Heelr?

Please contact us if you would like to seek access to, or request that we correct, the personal information we hold about you or your child by emailing info@heelr.com.au.

Heelr will generally provide you with access to your personal information if practicable, and will take reasonable steps to amend any personal information about you which is inaccurate or out of date.  If your child is aged under 15 at the time of making the request, Heelr will generally, depending on the nature of your request, provide you with access to your child's personal information if practicable, and will take reasonable steps to amend any personal information about your child which is inaccurate or out of date.  If your child is aged 15 or over at the time of making the request, Heelr will generally not provide you with access to your child's personal information or consider a correction request from you and will require your child to seek access to, or request correction of, their personal information themselves. 

In some circumstances and in accordance with the Privacy Act, Heelr may not permit access to your personal information or your child's personal information, or may refuse to correct your personal information or your child's personal information, in which case we will provide you or your child (as the case may be) with reasons for this decision.

How Heelr handles complaints

If you or your child have any concerns or complaints about the manner in which your personal information or your child's personal information has been collected or handled by Heelr, please advise us of the concern or complaint in writing and send it to info@heer.com.au. The concern or complaint will be considered or investigated and we will respond to the complaint as soon as practicable.

If you or your child remain dissatisfied with our response, you or your child may contact the Office of the Australian Information Commissioner (OAIC). The OAIC responds to complaints about the misuse of personal information. 

To lodge a complaint with the OAIC:

· Fill out a complaint form online at https://www.oaic.gov.au/; and

· Send the complaint form by:

»              Email at enquiries@oaic.gov.au;

»              Mail to GPO Box 5218, Sydney NSW 2001; or

»              Fax to 02 9284 9666.

Further information

Further information about the application of the Privacy Act can be found at the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

Changes to our Privacy Policy

This Privacy Policy is effective from 3 October, 2022. As this Privacy Policy is updated from time to time, to obtain a copy of the latest version at any time, you should visit our website at www.heelr.com.au.