Privacy Policy
1. Introduction
1.1 UP AT HOME PTY LTD (ACN 643 942 027) (we, us, our) recognises the importance of
protecting the privacy and the rights of individuals in relation to their personal information.
1.2 This privacy policy sets out our commitment to protecting the privacy of your personal
information and how it is collected whether through our website at
universalpracticeapp.com.au (Site) and our Universal Practice App (App), directly from you or
1.3 We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and the
Australian Privacy Principles, and we manage the collection and disclosure of your personal
information in accordance with these requirements.
1.4 If you do not wish to provide personal information to us, then you do not have to do so.
However, this may affect your use of the Site, the App and any services offered on it.
2. What is your personal information?
2.1 When used in this privacy policy, the term “personal information” has the meaning given to it
under the Privacy Act.
2.2 In general terms, it is any information that can be used to personally identify you. This may
include your name, address, telephone number, email address and profession or occupation.
2.3 If the information we collect personally identifies you, or you are reasonably identifiable
from it, the information will be considered personal information.
2.4 We may also collect some information that is not personal information because it does not
identify you or anyone else. For example, we may collect anonymous answers to surveys or
aggregated information about how users operate on our Site and App.
2.5 Your personal information will not be shared, sold, rented or disclosed other than as
described in this privacy policy.
3. What information we may collect from you
3.1 We may collect the following personal information from you:
a. names;
b. email address;
c. telephone number;
d. medical and health information;
e. fitness levels;
f. biodemographics;
g. billing, mailing, business and/or residential address;
h. banking, credit card, or other online payment details to process purchases;
i. date of birth;
j. various forms of identification; and
k. emergency contact details, including next of kin.
3.2 We collect personal information about you so that we can perform our business activities
and functions and to provide best possible quality of customer service. We collect, hold, use
and disclose your personal information for the following purposes:
a. to provide our App and services and to you;
b. to allow us to conduct our business functions;
c. to conduct internal record keeping;
d. to identify and understand user needs;
e. to enable us to process your personal data;
f. to personalise and customise your experiences on our Site and App;
g. to send communications requested by you;
h. to answer your enquiries, via email or the chatbot feature of the App, and provide
information or advice;
i. to conduct market research, business development and marketing activities (including
direct marketing);
j. to send you promotional information about our App and services;
k. to comply with any law, rule, regulation, lawful and binding determination, decision or
direction of a regulator, or in cooperation with any governmental authority; and
l. for our internal administrative, marketing and planning requirements.
4. How do we collect your personal information?
4.1 We collect your personal information directly from you unless it is unreasonable or
impracticable to do so. When collecting personal information from you, we may collect in
ways including:
a. when you make an enquiry about our App and the services provided by the App;
b. when you fill in any of our online forms or enrolment forms on the App;
c. through your access and use of our App, including when you create an account;
d. during communications between you and our representatives, through any means,
such as via email or the chatbot feature of the App;
e. when you ask to be placed on one of our subscription/mailing lists; and
f. when you become a client or customer of ours or otherwise use our App and its
5. What happens if we can’t collect your personal information?
5.1 If you do not provide us with the personal information described above, some or all of the
following may happen:
a. we may not be able to provide our App or services to you, either to the same standard
or at all;
b. we may not be able to provide you with information about the App or its services that
you may want, including information about special promotions; or
c. we may be unable to tailor the content of our App to your preferences.
6. Our Site
Site User Tracking Experience
6.1 We may use tracking software to review and improve your experience of our Site, Surveys
and landing pages. In particular, we may use Facebook Pixel, Infusionsoft, Active Campaign,
Google Analytics, YouTube, etc.
6.2 When visiting our Site, the site server makes a record of the visit and logs the following
information for statistical and administrative purposes:
a. the user’s server address – to consider the users who use the site regularly and tailor
the site to their interests and requirements;
b. the date and time of the visit to the site this is important for identifying the Site’s
busy times and ensuring maintenance on the site is conducted outside these periods;
c. pages accessed and documents downloaded this indicates to us which pages or
documents are most important to users and also helps identify important information
that may be difficult to find;
d. duration of the visit this indicates to us how interesting and informative the our site
is to users;
e. the type of browser used this is important for browser specific coding; and
f. in order to optimize our Site and better understand it’s usage, we collect the visiting
domain name or IP address, Computer Operating System, Browser Type and Screen
6.3 We may use advertising products, such as Remarketing with Facebook, Google Analytics and
Google Analytics Demographics and Interest Reporting. Google Analytics collects data about
our Site traffic via Google Advertising cookies and anonymous identifiers.
6.4 Data collected via these Google products is not linked with any personally identifiable
information you submit while on our Site. If you wish to opt out of the Google Analytics data
collection, you may do so on Google’s Site at tools.google.com/dlpage/gaoptout.
6.5 When you access our Site, we may send a “cookie” (which is a small summary file containing
a unique ID number) to your computer. This enables us to recognise your computer and greet
you each time you visit our Site without bothering you with a request to register. It also
enables us to keep track of services you view so that, if you consent, we can send you news
about those services.
6.6 We also use cookies to measure traffic patterns, to determine which areas of our Site have
been visited and to measure transaction patterns in the aggregate.
6.7 We use this to research our users’ habits so that we can improve our online services. Our
cookies do not collect personal information. If you do not wish to receive cookies, you can set
your browser so that your computer does not accept them. We may log IP addresses (that is,
the electronic addresses of computers connected to the Internet) to analyse trends,
administer the Site, track users’ movements, and gather broad demographic information.
6.8 The Site may contain content and sharing tools embedded from various social networks, such
as Facebook. These suppliers may use and place cookies on your device. We do not have
access to, and cannot control, these cookies or the personal data and information that they
may collect. You therefore need to check the websites of these suppliers to get further
information on how they manage cookies and what information their cookies collect.
6.9 As our App and our Site is linked to the internet, and the internet is inherently insecure, we
cannot provide any assurance regarding the security of transmission of information you
communicate to us or upload to the App.
6.10 We also cannot guarantee that the information you supply will not be intercepted while
being transmitted over the internet. Accordingly, any personal information or other
information which you transmit to us online is transmitted at your own risk.
6.11 We may provide links to websites outside of our Site or App, as well as to third party
websites. These linked sites are not under our control, and we cannot accept responsibility
for the conduct of any companies, businesses, affiliates, advertisers and sponsors, linked to
our Site.
6.12 Before disclosing your personal information on any other website or to any third party, we
advise you to examine the terms and conditions of using that websites and its privacy policy.
Third party websites are responsible for informing you about their own privacy practices.
7. Who do we disclose your information to?
7.1 We may disclose your personal information to:
a. our directors, employees, agents, contractors or service providers, including, without
limitation, consultants web hosting providers, IT systems administrators, mailing
houses, couriers, payment processors, data entry service providers, electronic network
administrators, debt collectors, and professional advisors such as accountants,
solicitors, business advisors, for the purposes of operating our Site or our business,
fulfilling requests by you, and to otherwise provide services to you;
b. suppliers and other third parties with whom we have commercial relationships, for
business, marketing, and related purposes, which may include overseas parties;
c. credit reporting agencies and courts, tribunals, regulatory authorities where customers
fail to pay for goods or services provided by us to them, and other law enforcement
officers as required by Law; and
d. any other organisation for any authorised purpose with your express consent.
7.2 We only disclose this information if the third party has agreed to comply with the standards
in our privacy policy.
7.3 If there is any change or potential change to the control of our business pursuant to the sale,
assignment or transfer of the business, or business assets, its assets and/or liabilities, we
reserve the right to sell, assign and/or transfer our user databases, together with any
personal information and non-personal information contained in those databases to the
extent permitted by law. In that event, your personal information may be disclosed to a
potential purchaser, assignee or transferee, however any disclosures will only be made in
good faith and where confidentiality is maintained.
8. Direct marketing materials
8.1 We may send you direct marketing communications and information about our services that
we consider may be of interest to you. These communications may be sent in various forms,
including mail, SMS and email, in accordance with applicable marketing laws, such as the
Spam Act 2003 (Cth).
8.2If you indicate a preference for a method of communication, we will endeavour to use that
method whenever practical to do so.
8.3 In addition, at any time you may opt-out of receiving marketing communications from us by
contacting us (see the details below) or by using opt-out facilities provided in the marketing
communications and we will then ensure that your name is removed from our
subscription/mailing list.
8.4We do not provide your personal information to other organisations for the purposes of
direct marketing.
9. Security and data quality
9.1 We take reasonable steps to ensure your personal information is protected from misuse and
loss and from unauthorised access, modification or disclosure.
9.2 We strive to ensure the security, integrity and privacy of personal information that you
submit to us through our App and our Site. Unfortunately, no data transmission over the
Internet can be guaranteed to be totally secure.
9.3 We endeavour to take all reasonable steps to protect the personal information you may
transmit to us. Once we do receive your transmission, we will also make our best efforts to
ensure its security on our systems.
9.4 In addition, our employees and the contractors who provide services related to our
information systems are obliged to respect the confidentiality of any personal information
held by us.
9.5 We may hold your information in either electronic or hard copy form. Personal information is
destroyed or de-identified when no longer needed or when we are no longer required by Law
to retain it (whichever is the latter).
9.6 Should a data breach involving personal information occur:
a. We will take positive steps to address the breach in a timely manner and take remedial
action such that the data breach does not result in serious harm.
b. We will undertake reasonable and expeditious assessment to determine if it is an
‘eligible data breach’, that is a breach likely to result in serious harm to any individual
9.7 In compliance with Privacy Amendment (Notifiable Data Breaches) Act 2017, we agree that if
we become aware of reasonable grounds to believe an eligible data breach has occurred we
will promptly notify the Office of the Australian Information Commissioner (Commissioner),
the Association of Market and Social Research Organisations (AMSRO) and the affected
individuals at likely risk of serious harm.
10. How long do weretain your personal data?
10.1 We will only keep your personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
10.2To determine the appropriate retention period for personal data, we consider the amount,
nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use
or disclosure of your personal data, the purposes for which we process your personal data
and whether we can achieve those purposes through other means, and the applicable legal
10.3 By Law, we must keep basic information about our customers (including contact, identity,
financial and transaction data) for five years for Australian tax law purposes.
10.4 In some circumstances, you can ask us to delete your data; see your legal rights below for
further information.
10.5 In some circumstances we may anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this
information indefinitely without further notice to you.
11.How can you access and correct your personal information?
11.1 You may request access to any personal information we hold about you at any time by
contacting us (see the details below).
11.2 Where we hold information that you are entitled to access, we will try to provide you with
suitable means of accessing it (for example, by mailing or emailing it to you).
11.3 We may charge you a reasonable fee to cover our administrative and other reasonable costs
in providing the information to you.
11.4 We will not charge for simply making the request and will not charge for making any
corrections to your personal information.
11.5 There may be instances where we cannot grant you access to the personal information we
hold. For example, we may need to refuse access if granting access would interfere with the
privacy of others or if it would result in a breach of confidentiality. If that happens, we will
give you written reasons for any refusal.
11.6 If you believe that personal information we hold about you is incorrect, incomplete or
inaccurate, then you may request us to amend it. We will consider if the information requires
correction. If we do not agree that there are grounds for correction, then we will add a note
to the personal information stating that you disagree with it.
12.How can you withdraw your consent to this privacy policy?
12.1 You may withdraw your consent to this privacy policy at any point. If you wish to withdraw
your consent to our collection and retention of your data, please contact our Data Protection
Officer at theapp@universalpractice.com.au and we can arrange for your data to be deleted,
destroyed or returned to the extent we are permitted by law. However, this may affect your
use of this Site or any products and services offered on it.
12.2 You may choose to restrict the collection or use of your personal information. If you have
previously agreed to us using your personal information for direct marketing purposes, you
may change your mind at any time by contacting us at the email address listed in this privacy
12.3 To unsubscribe from our e-mail database, or opt out of any communications, please contact
us at the email address listed at the start of the privacy policy, with “Unsubscribe” in the
subject line of the e-mail.
13.What is the process for complaining about a breach of privacy?
13.1 If you believe that your privacy has been breached, please contact us using the contact
information below and provide details of the incident so that we can investigate it.
13.2 We will treat your complaint confidentially, investigate your complaint and aim to ensure
that we contact you and your complaint is resolved within a reasonable time (and in any
event within the time required by the Privacy Act).
14.Contacting us
14.1 If you have any questions about this privacy policy, any concerns or a complaint regarding
the treatment of your privacy or a possible breach of your privacy, please contact us at
14.2 We will treat your requests or complaints confidentially.
14.3 Our representative will contact you within a reasonable time after receipt of your complaint
to discuss your concerns and outline options regarding how they may be resolved.
14.4 We will aim to ensure that your complaint is resolved in timely and appropriate manner.
15.Changes to our privacy policy
15.1 All Personal Information held by us will be governed by our most recent privacy policy,
posted on our Site, where the privacy policy will be located.
15.2 Any changes to this privacy policy may be advised to you by updating this page on our Site.
We encourage you to check this page from time to time for any changes. © Progressive Legal
Pty Ltd (ACN 607 068 708) trading as Progressive Legal (2021). All Rights Reserved. This
privacy policy was last updated 18 June 2021.