PRIVACY POLICY

Last updated:  Apr 15, 2024

 

The AdamGuthrie.com website and all other associated services (Services) are owned by I Feel Good Pty Ltd and our other related entities (us, we, our).

Your privacy is important to us, which is why we want to make sure that any personal information you give to us while using our Services is well protected. Before interacting with our Services, please read this Policy which sets out what information we collect from you and how we use it. Please note that this Policy forms part of the Terms of Use which you accept and agree to by continuing to use our Services.

By providing us with Personal Information, to the extent consent is required by us, you consent to our use of that information in accordance with this Policy.

 

What information do we collect and hold?

We may collect and hold a variety of information from you while using our Services. This may include information which can be used to personally identify you (Personal Information). Some types of Personal Information we may collect, depending on your use of the Services, includes your:

  1. name;
  2. age and date of birth;
  3. e-mail address;
  4. street address;
  5. telephone number and other contact details;
  6. credit card details;
  7. bank account details; and
  8. photographic identification.

We may also collect and hold other information about your interaction with our Services, which may or may not include Personal Information, such as:

  1. data which provides descriptive, technical, statistical and other metadata type information regarding your use of our Services;
  2. feedback about the progress or outcomes of any of our services purchased.
  3. purchase and enquiry history with us;
  4. evidence of accreditations, employment history, licenses, qualifications and criminal history; and
  5. any other information you disclose to us through interacting with the Services, our support team, message boards, surveys, promotional offers, reviews or otherwise.

It is optional for you to provide us with Personal Information. However, we may not be able to provide some or all of our Services to you without certain Personal Information.

 

How do we collect Personal Information?

How we collect and store your Personal Information depends on which Services you use and how you choose to interact with them.

We generally collect Personal Information directly from you in the following ways:

  1. through your use of our Services;
  2. through communications between you and our representatives or support team;
  3. whenever you create an account with us;
  4. whenever you make purchases through us;
  5. whenever you participate in our promotional offers or surveys; and
  6. whenever you provide us with feedback or any other information or documentation about our Services.

We may also collect your Personal Information from third parties such as:

  1. our business partners and contractors, such as those who provide promotional offers related to us;
  2. social media sites where you have connected your account with our Services or where you have visited our social media pages such as those on Twitter and Facebook; and
  3. advertisers;
  4. government bodies, departments or agencies; and
  5. mailing lists. 

 

How do we collect Personal Information?

We take the security and confidentiality of your Personal Information very seriously.

Any Personal Information held by us is securely physically stored on our business premises in Australia and/or stored digitally on the cloud or third party servers. Stored Personal Information about you may be combined or linked with any other information about you that we hold about you, including any information we receive from third parties.

We have taken all reasonable steps, including implementing a number of industry standard security systems and protocols, to prevent any misuse, loss, interference, modification or unauthorised access or disclosure of Personal Information held by us or our data processors.

We will only retain your Personal Information for as long as necessary to fulfil the purpose/s for which the Personal Information was obtained or, as applicable, for any other purpose you have consented to or for our legitimate business purposes as outlined in the section below.

We may however retain your Personal Information for a period longer than above where necessary for us to fulfil any legal obligation or in order to protect the vital interests of yourself or another person.

 

What do we use Personal Information for?

We hate junk mail as much as you do - we will never share, sell or rent your Personal Information to third parties other than as disclosed in this Policy.

We collect, hold, use and disclose Personal Information and other information for the following legitimate business purposes:

  1. to assess your identity and eligibility for the Services;
  2. to provide the Services;
  3. to provide you with updates on the Services;
  4. to provide you with news and information on promotional offers or competitions, upcoming events and products offered by us or our business partners;
  5. to provide support and communicate to you as our customer;
  6. to manage any accounts you have with us;
  7. to process payments, transactions and delivery of orders to you;
  8. to collect and pay any amount on your behalf or to make a payment to you;
  9. to provide information to our related bodies corporate in order to carry out our business operations;
  10. to our third party external service providers such as our data hosting partners and IT service providers, online store host and customer support team in order for our Services to be provided;
  11. to display content and/or advertising that is relevant to you;
  12. our marketing, planning, research, maintenance and administrative purposes;
  13. to provide to third parties where disclosed to you in this Policy or otherwise where authorised by you;
  14. to provide to our third party payment service providers as necessary to process a payment to or from you;
  15. to our marketing tool provider/s to allow us to maintain our customer and mailing list database;
    to investigate any complaint made by or against you or to investigate any unlawful or improper use of our Services;
  16. to obtain an overview of how you use our Services and for profiling so that we may provide advertising more relevant to you;
  17. to intervene in and resolve disputes between you or us and another person;
  18. as part of a transfer of our assets should we propose or proceed to sell, merge or otherwise alter ownership of our business;
  19. to initiate or respond to a claim or other legal action;
  20. as otherwise required in connection with providing the Services;
  21. to monitor and improve the Services;
  22. to exercise or defend our rights, including disclosing information to credit reporting agencies, courts, tribunals and other regulatory agencies; and
  23. as permitted or required by law.

If you are an European Economic Area (EEA) resident, please note that we process your Personal Information to the extent necessary to carry out our legitimate business purposes and interests as listed above or otherwise, unless we are required by law to obtain your consent to process your Personal Information in a specific way, in which case we will rely on any consent obtained from you in order to carry out that processing. Depending on how you use our Services, processing of your Personal Information may also be necessary in order for us to fulfil contractual obligations to you (such as where you have placed an order with us), and we will rely on this as the basis for carrying out that processing. We may also process your Personal Information in order to comply with a legal obligation, protect your vital interests, or as may be required of us for the public good.

When Personal Information is disclosed by us to our related entities or third parties as listed above, Personal Information will only be disclosed to that party to the extent necessary for the disclosure purpose identified in the list above to be carried out by that party.

Where we determine it is commercially viable to do so, we will attempt to carry out any of the above listed purposes without using Personal Information or by de-identifying Personal Information first, so that an individual cannot be recognised by that information.

Except where retention is required by law, we will take reasonable steps to de-identify or destroy any Personal Information where it is no longer needed for the purposes provided for in this policy.

 

What do we use Personal Information for?

Whilst you are using our Services, we, our advertisers, business partners and other third parties may also collect and hold other information by using cookies or other technologies. Cookies allow tracking and storage of information about your use of the internet and our Services either directly or through third parties, such as Google Analytics.

In some cases, you can choose not to provide us with information by setting your browser to refuse cookies, however this may restrict your ability to fully interact with our Services. Where cookies are not mandatory in order for our Services to be provided, we will request your consent to our use of cookies when you first use our Services.

Cookies are used by us for various reasons including to:

  1. store your username and password for any account you hold with us on a device so you do not have to re-enter it;
  2. generate statistical information and reports about your use of the internet and our Services;
  3. to understand your interests, demographic and location details to provide you with a more customised experience when using our Services;
  4. to personalise advertising to suit your interests and prevent the same advertisement appearing to you repeatedly; and
  5. to combine information about your usage patterns with similar information obtained from other users to help enhance our Services (e.g. to learn which pages are visited most or what features are most attractive).

We may also implement other technologies to obtain information for reasons similar to those above. This information may occasionally be shared with our advertisers and business partners, but this does not include Personal Information. However, please note that we cannot control or be responsible for the use of cookies or other technologies implemented by third parties.

Comments, promotional offers, blogs, advice, opinions or any other content or website that is created or hosted by a third party, but is accessed by you via our Services (through embedding, hyperlink or otherwise), may be subject to that third party's own privacy and data collection policies and practices which may vary from our own.

If you voluntarily disclose Personal Information via a publicly accessible feature of our Services (such as a message board), you do so at your own risk, as this information may be publicly available around the world and third parties may access and use this Personal Information to send you unsolicited material or otherwise use your Personal Information in a manner we cannot control.

You may interact with third parties in connection with our Services. Any services or content provided by a third party may be subject to that party's own privacy and data collection policies and practices which may vary from our own.

Please do not provide us with Personal Information of a third party unless requested by us. If you provide us with Personal Information about a third party, you warrant that you have the consent of that third party to provide that Personal Information.

We may use automated decision making or profiling technologies from time to time. This is to allow us to show you content or marketing which is more personalised. If you are an EEA resident, please note that these technologies will not be used in a way that would have a significant effect on you, unless such use is necessary to fulfil a contractual obligation we have to you, your consent to such use has been obtained or we are required to use those technologies in that manner by law.

 

International Disclosure of Personal Information

We carry on our business operations internationally. Our head office is based in Australia however we also have business facilities, employees, contractors and third party service providers located worldwide, including in the United States. Accordingly, we may disclose your Personal Information outside of Australia and outside of the EEA for any of the purposes identified in this Policy, but mainly to our support team, data hosting provider and order processing teams for the purposes of providing the Services.

We take reasonable steps to ensure that overseas recipients handle your Personal Information in accordance with our Policy. Specifically, if you are an EEA resident, we ensure that the transfer of your Personal Information to any country outside of the EEA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the European Commission website, by ensuring the recipient has adopted binding corporate rules or ensuring that the recipient provides an appropriate level of data protection based on an adequacy decision of the European Commission.

 

Accessing, updating and deleting your Personal Information

You have a right to request access to and seek correction of any Personal Information we hold about you, such as information which you believe is incorrect, incomplete, outdated, misleading or irrelevant. You may also request additional information from us regarding the purposes for which we process your Personal Information and the types of third parties to whom we disclose your Personal Information.

You may access and amend your Personal Information by logging into any account you have with us via the Services or by sending us an email via the contact details at the end of this Policy. We may charge a reasonable access fee if multiple requests for access are made by you.

If you are an EEA resident, in addition to the above, you have the following rights in relation to your Personal Information:

  1. the right to withdraw consent or 'opt out' from us processing your Personal Information (the lawfulness of processing prior to the withdrawal of consent will not be affected);
  2. the right to have us delete your Personal Information from our database without undue delay if you withdraw your consent (where our use was based on consent) or the information is no longer required for the purpose/s for which it was obtained;
  3. the right to restrict how we process your Personal Information, such as where the information is inaccurate or the use is unlawful;
  4. the right to receive access to your Personal Information as held by us, in a form that is accessible and commonly used;
    5. the right to object to the processing of your Personal Information in a particular way (including direct marketing purposes, profiling or automated decision making for direct marketing purposes).

The above is a summary of your rights only, for example, some rights may only be exercisable in certain circumstances or our obligation to fulfil your request may be subject to certain exemptions. You should make your own enquiries into the full extent of your rights at law.

If you wish to exercise any of the above rights in relation to your Personal Information, you can make this request via the email or postal contact details at the end of this Policy. Where applicable to you, some of the above rights, such as to 'opt out' of further emails from us or to delete the Personal Information held by us can be carried out by deleting your account with us or clicking the 'unsubscribe' link at the bottom of an email from us.

 

Complaints

If you have complaints, comments or concerns regarding the Act or this Policy, please first contact us directly via the details at the end of this Policy. We will endeavour to get back to you as soon as possible, but we ask that you allow us up to 30 days to respond before taking any other action. We will investigate your complaint in a timely manner and advise you of the outcome of our investigation, including what steps, if any, we propose to take to handle or remedy your complaint.

If you are an EEA resident, despite the above, you have the right to complain directly to a supervisory authority which is responsible for data protection at any time.

 

Contact Details

For any queries relating to this Policy, please contact:

If you live within the European Economic Area
I Feel Good EEA Privacy Officer

[email protected]

If you live outside of the European Economic Area
I Feel Good Privacy Officer

I Feel Good Pty Ltd
Po Box 422
Byron Bay, NSW
Australia 2481

+ 61 416091641

[email protected]

 

Updates

We may update this Policy from time to time; the most current version of this Policy will always apply. We may notify you of updates to this Policy by email or the Services from time to time.