We recognise the importance of protecting and maintaining your personal and sensitive information. Any personal or sensitive information that we collect or hold about you will only be used for the purposes for which we have collected it, or as allowed by law. We will take reasonable steps to protect your personal and sensitive information from unauthorised access, misuse, loss and unauthorised disclosure or modification.
We are committed to providing you with the highest quality professional service while protecting your privacy and abiding by the Australian Privacy Principles established under Australian Law and the General Data Protection Regulation in the European Union (“GDPR”) while also encouraging you to interact with and share information about your progress with others while using the Services.
INFORMATION WE COLLECT
We may collect the following information from you:
Protected Health Information. “Protected Health Information” is a subset of Personal Information that includes information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health or condition; related health care services; or related to the past, present, or future provision of health care to you.
Sensitive Information. “Sensitive Information” is a subset of Personal Information and includes any information about your racial or ethnic origin or health information.
We may also collect other information about you that is not Personal Information.
HOW WE COLLECT PERSONAL INFORMATION AND OTHER INFORMATION
We receive and/or collect Personal Information and other information from you in the following ways:
when you register for and/or use the Services;
when you interact with the Services; and
when you otherwise contact Defeat Diabetes.
Defeat Diabetes may collect certain information such as your height, weight, blood pressure, blood glucose and gender and display your biometrics to you based on these inputs.
In addition to any Personal Information or other information that you choose to submit to Defeat Diabetes, Defeat Diabetes and its third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Website (“Usage Information”). This may include:
your IP address or any unique identifier for your personal computer, browser, laptop, tablet, mobile phone or other similar device (“Device”). such as any number that is automatically assigned to your Device used to access the Website; Your Device’s functionality (including browser, operating system, hardware, mobile network information);
your subscription level;
the URL that referred you to the Website;
the areas within Defeat Diabetes’ Website and/or Mobile App that you visit and your activities there, including remembering you, your preferences and pages you requested and/or viewed;
your Device’s location;
your Device’s characteristics; and
certain other non-identifiable data, including the time of day, among other information.
Defeat Diabetes may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. The Tracking Technologies that may be used include the following (and subsequent technology and methods later developed which perform a similar function):
Cookies. A cookie is a data file placed on a Device when it is used to visit the Website. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s web site www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of the Services may not function properly, and that when you revisit either the Website or Mobile App, your ability to limit cookies is subject to your browser settings and limitations.
Web Beacons. Small graphic images or other web programming code called “web beacons” (also known as “1×1 GIFs” or “clear GIFs”) may be included in pages and messages of our Website or Mobile App. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website or Mobile App, to monitor how users navigate the Website or Mobile App, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Website or Mobile App, such as the links you click on. The code is temporarily downloaded onto your Device from Defeat Diabetes’ web server and/or Mobile App or a third-party service provider is active only while you are connected to the Website and/or Mobile App, and is deactivated or deleted thereafter.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Defeat Diabetes uses Tracking Technologies for a variety of purposes, including:
Information From Third Parties
WHY WE COLLECT PERSONAL INFORMATION AND OTHER INFORMATION
HOW WE USE YOUR PERSONAL INFORMATION
Defeat Diabetes may use your information :
to provide you with services;
to contact you occasionally to inform you of new Services features, or news, articles or updates that Defeat Diabetes thinks will be of interest to you.
to contact you with regard to your use of the Services and, in Defeat Diabetes’ discretion, to inform you of changes to the Services and/or any of Defeat Diabetes’ policies;
for internal business purposes;
to provide you with information or services or to process transactions that you have requested or agreed to receive including to send you electronic newsletters;
to provide you with marketing materials or relevant advertising, promotions and recommendations from Defeat Diabetes or our business partners;
to enable you to participate in a variety of the Service features;
to process your account registration, including verifying your information is active and valid;
to identify you as the author of any comments that you send to Defeat Diabetes to be posted on the Website or Mobile App;
to ensure that content on the Website and Mobile App is presented in the most effective manner for you and for your computer, tablet or mobile device;
to provide you with information relating to any events held by Defeat Diabetes, where you have consented to be contacted for such purposes;
to personalise your experience on the Website or Mobile App;
to help diagnose and resolve technical and service problems;
to determine what areas and features of the Services are most popular, and to make improvements, updates to the user experience (including market research and trend analysis) and how we may tailor our Services to better meet the needs of our users; and
to provide you with access to your personal account on our Website and/or Mobile App.
Unless we provide you with specific notice, we will not use or disclose your personal information other than for the primary purpose for which it is collected, unless you would reasonably expect us to use or disclose the information for a secondary purpose or your consent has been collected to use the information for additional purposes.
We may send you information and communications about our products and services that we consider may be of interest to you. We may send this in various forms, including mail, SMS and email, in accordance with applicable laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
In addition, at any time you may opt-out of receiving marketing communications from us by contacting us by email at firstname.lastname@example.org or by using opt-out facilities provided in the marketing communications. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
We may create anonymous data records from your personal information by completely excluding information (such as your name) that makes the data personally identifiable to you. Typically, we use this anonymous data to analyse request and usage patterns so that we may enhance the content of our services and improve functionality. We may use anonymous data for any purpose and disclose anonymous data to third parties at our sole discretion.
We adopt all relevant exemptions permitted under Australian law in relation to employee records.
We will not disclose sensitive information unless it is necessary for us to conduct our business with you. However, if you elect to provide us with unsolicited sensitive information, it may be retained.
Disclosure of Information To Third Parties
Defeat Diabetes may share your Personal Information, including performance measurement information associated with your name that is collected or generated through the Services, with third parties.
Personal Information may occasionally be transferred to third parties who act for Defeat Diabetes for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have subsequently consented. For example, sometimes a third party may have access to your Personal Information in order to support Defeat Diabetes’ information technology or to handle mailings on Defeat Diabetes’ behalf. If Defeat Diabetes transfers your Personal Information to an outside agent or organisation for such purpose, Defeat Diabetes will take appropriate measures in an effort to protect your privacy and the Personal Information Defeat Diabetes transfers.
Defeat Diabetes may share your Personal Information with its various business partners. Some of these business partners may use your personal information to facilitate the offering of services or products that may be of interest to you. We may also share your Personal Information as otherwise described to you at the time of collection.
Defeat Diabetes may, in its sole discretion, share or transfer Personal Information where permitted or required by law, to comply with legal process, to interact with anti-fraud databases, to protect your vital interests, to protect the security or integrity of Defeat Diabetes’ databases, Website or Mobile App, to enforce the Terms & Conditions or to protect the business or reputation of Defeat Diabetes and/or its Business Customers, to take precautions against legal liability, to protect and defend the rights or property of Defeat Diabetes and/or its Business Customers, for required institutional risk control, or for resolving disputes, inquiries or complaints with respect to your use of the Services.
User-Generated Content and Public Information.
Defeat Diabetes or others may store, display, reproduce, publish, distribute or otherwise use any content, materials or information (including without limitation, any text, information, graphics, messages, photos, images, nutritional information contributed to the Food Database and works of authorship kind), data, questions, comments, suggestions or other content, including personally identifiable information that you upload, send, email, display, perform, distribute, post or otherwise transmit to us, at our request or on your own, on, or through the Services (such as message boards, recipe logging), whether in connection with your use of the Services or through the use of any Third Party Websites or Third Party Services or otherwise, and whether publicly posted or privately transmitted (“User Content”) online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Be aware that public postings (including group messaging with other users) are not confidential. Please note that Defeat Diabetes does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. Defeat Diabetes is not responsible for the privacy or security of any information that you make publicly available on the Services, or what others do with information you share with them on the Services. Defeat Diabetes is not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Services.
Name and Likeness.
Defeat Diabetes may also use your name, voice, likeness and other Personal Information that is part of your User Content, and Defeat Diabetes may use such content, or any portion of such content, for advertising, marketing, publicity and promotional activities, provided that Defeat Diabetes will not exercise such rights as to any User Content which identifies you in a public manner (other than in providing the Services to the Business Customer and the Business Customer’s other participants) unless you provides a separate consent to Defeat Diabetes in writing (email is sufficient) authorising such use. For full terms and conditions regarding User Content, please review Defeat Diabetes’ Terms & Conditions.
Your profile page on our Mobile App may be, by default, set up to display information such as your display name, images, location (city/state/country), groups that you have joined and optional information added by you. Profile information is used by Defeat Diabetes primarily to be presented back to and edited by you when you access the Services and to be presented to others permitted to view that information. Defeat Diabetes may offer users the ability to manage their public profile and use profile preference settings, the functionality and features of which are subject to change from time to time. Defeat Diabetes recommends that you do not post information or content as part of your profile that you are not prepared to make public. Notwithstanding the availability of profile preference settings, you should be aware that these settings are for convenience only, do not employ complex data security protection and may not be error free. Further, other users may repost or otherwise make public your information or content. Accordingly, discretion and good judgment should be exercised when posting information or content as part of your profile.
Use of Anonymous Information.
We may use information which does not enable identification of an individual user, such as aggregated information about use of the Services. (“Anonymous Information”), or disclose such information to third party service providers, to provide and improve the Services. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners, for purposes including, but not limited to, targeting advertisements.
You may choose not to receive future promotional, advertising, or other Service-related notifications from us by changing the notification settings on your device or your preferences on the Website or Mobile App. If you choose not to receive notifications, you may still use the Services but you may not receive, or may be unable to use, certain aspects of the Services that require our interaction with you.
At all times, you may choose whether or not to provide or disclose Personal Information to us. It is entirely voluntary. If you choose not to provide Personal Information to us, you may still use the Services, but you may be unable to access certain aspects of the Services that require your Personal Information or may experience reduced functionality if you do not provide your Personal Information.
Collection of Information by Third-Party Websites.
Links to Other Websites.
The Services may contain links to third-party websites that are not owned or controlled by us. We do not have control over and are not responsible for the privacy practices or the content of such other third-party websites and encourage you to review the particular privacy policies of such third party websites.
The Services are neither directed to nor structured to attract children under the age of 18 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years of age. We will direct potential users under 18 years of age not to use the Services. If we learn that Personal Information of persons less than 18 years of age has been collected without verifiable parental consent, then we will take the appropriate steps to delete this information as soon as possible.
Security and Storage.
The security of your Personal Information is important to us. We may hold your information in either electronic or hard copy form. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to keep information that we collect secure and protected from unauthorised disclosure or other access, misuse, interference and loss. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about our security, you can contact us at email@example.com.
Please be aware that certain Personal Information and other information provided by you in connection with your use of the Services may be stored on your Device (even if we do not collect that information). You are solely responsible for maintaining the security of your Device from unauthorised access.
We store your Personal Information in an encrypted database on password-protected servers located in the cloud.
Defeat Diabetes Service: International Users
In the event Defeat Diabetes goes through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of its assets, your Personal Information might be transferred. You will be notified by us of any such change in ownership or control of your Personal Information.
We will only retain your Personal Information for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting or reporting requirements or to comply with our data retention practices.
Access and Accuracy
To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to access, delete or correct any other of your Personal Information that we may be storing, you may submit a request to us by sending an email to firstname.lastname@example.org. Your email should include adequate details of your request.
If we decline to correct your Personal Information, we will provide you with our reasons for not doing so.
If you believe that we have breached our obligations, please contact our Privacy Officer in writing. We will respond to you within 30 days. If you are not satisfied with our response, you may raise your complaint to the Office of the Australian Information Commissioner (email@example.com).
Contacting us and changes to this policy
Defeat Diabetes Customer Services
Level 4/100 Albert Road, South Melbourne, VIC2305
Last Updated: November 3, 2020
ANNEXURE – Notice to Residents of the European Union
How to exercise your rights
Defeat Diabetes takes steps to keep your Personal Information accurate and up to date. If you reside in the European Union, you have certain rights to the Personal Information that we have collected about you. To exercise your rights to your Personal Information, please contact us at GDPRsupport@Defeat Diabetes.com or at the address listed below. Subject to applicable law and in exceptional circumstances only, we may charge for this service and we will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.
Right to lodge a complaint before the Data Protection Authority
We encourage you to contact us directly and allow us to work with you to address any concerns you may have. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in the particular European Union Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Information relating to you infringes upon your rights under the GDPR.
Changes to this Notice to Residents of the European Union
In order to enhance our Website, Mobile App and/or other services it might be necessary to change this Notice to Residents of the European Union from time to time. We therefore reserve the right to modify this Notice to Residents of the European Union as required from time to time. Please visit our Website from time to time for any updates to this notice.
How to contact us or our privacy office as a Resident of the European Union
In case of questions about the processing of your Personal Information please contact us at:
Lvl 4 96-100 Albert Road, South Melbourne, VIC 3205