Respecting Your Privacy and the law

The privacy of your personal information has always been important to us at Betterlife Directions Pty Ltd (Betterlife Directions). We are committed to respecting your right to privacy and protecting your personal information. We arebound by Betterlife Directions's Privacy Policies, the Australian Psychological Society's Code of Ethics, the Employee Assistance Professional's Association of Australia's Code of Ethics, and the Australian Privacy Act 1988 (Commonwealth) and any other relvant Health Privacy Principles under state legislation, as well as other applicable laws and codes affecting your personal information. Our staff are trained to respect your privacy in accordance with our standards, policies and procedures.

About this Privacy Policy

Thie PrivacyPolicy outlines how we manage your personal information.

It also describes generally the sorts of personal infomation held and for what purposes, and how that information is collected, held, used and disclosed.

Our Privacy policy applies to all your dealings with us whether at one of our offices, over the phone, or via our website. However, depending on the business unit you deal with, further privacy informatio nmay apply in addition to the matters discussed in this Privacy Policy.

We encourage you to check our websites regularly for any updates to our Privacy Policy.

Collecting your Personal Information

If you are acuiring or have acquired a product or service from an Betterlife Directions business unit, it will collect and hold your personal information for the purposes of:

• providing you with the relevant product or service
• managing and administering the product or service
• maintaining clinical records if the product or service is of a clinical nature

Betterlife Directions may also collect your personal information for the purpose of letting you know about products or services that might better serve your personal, health or lifestyle needs or promotions or other opportunities in which you may be interested.

The information collected may include your name, postal or email address, date of birth, drivers licence number, medicare number, health information and/or mental health well-being information, or if you are in business information relating to the operation of your buseinss or other information Betterlife Directions considers necessary. The more information you share with us, the better we are able to assist you.

We will, if it is reasonable or practicable to do so, collect your personal information from you. This may happen when you fill out a product or service application, or a client registration form, or an administrative form (eg a change of address form), or when you give us personal information over the telephone or counter, or through one of our websites, or during the client registration process and admission to our service, or through making enquiries abour our services, or in a face to face consultation and so on.

In certain cases we collect your personal information from third parties. For example, we may need to collect personal information from your general practitioner, your representative (such as a legal advisor), your financial advisor, your employer or publicly available sources of information or any other organisation. We will seek your consent to obtain information from these sources prior to doing so.

Using and Disclosing your Personal Information

In line with modern clinical business practices common to many health organisation and to meet your specific needs (such as where you are being treated by a general practitioner) we may disclose your information to the organisations below. Where your personal information is disclosed we will seek to ensure that the information is held, used or disclosed consistently with the Betterlife Directions Privacy Principles, any relevant Health Privacy Principles under state legislation and other applicable privacy laws and codes.

The relevant organisations are those:

• which are Betterlife Directions business units who wish to tell you about their products or services that might better server your personal, health or lifestyle needs or promotions or other opportunities, and their related service providers, except where you tell us not to.
• who are your representative including your legal or financial advisors
• who are your treating medical practitioner or other treating health practitioner
• involved in the payments system including financial institutions, merchants and payment organisations (eg Visa or our merchant provider)
• as required or authorised by law, for example, to government or regulatory bodies for purposes related to public health or safety, the prevention or detaction of unlawful activities or to protect your health or wellbeing
• where you have given your consent

Marketing our products and Services

it is our pratice to seek your consent to use or disclose your personal information to let you know about, and develop, products and services from across Betterlife Directions's busienss units that might better serve your personal, health or lifestyle needs or promotions or other opportunities in which you might be interested. This may be done after and initial marketing contact. We assume we have your consent to use service providers to assist us with this (such as a posting service or an advertising agency), unless you tell us otherwise by contacting us at the contact details below.

Keeping your Personal Information Accurate and Up-to-date

We aim to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. We will take reasonable steps to make sure this is the case. This way we can provide you with better service.

If you believe your personal information is not accurate, complete or up-to-date, please contact us at the contact details below.

Protecting Your Personal Information

We store information in different ways, including in paper and electronic form. The security of your information is important to us and we take reasonable steps to protect it from misuse and loss and unauthorised access, modification or disclosure. Some of the ways we do this are:

• confidentiality requirements of our employees
• document storage security policies
• security measures for systems access
• providing a discrete environment for confidential discussions
• only allowing access to personal information where the individual seeking access has satisfied our identification requirements
• access control for our buildings
• the security measures described below in the Our Websites section

Sharing of your information:

Betterlife Directions will not sell or market your name, e-mail addresses, or any other privileged information about you, unless otherwise requested to do so by you.

Your Privacy on the Internet

Our Websites

We take care to ensure that the personal information you give us on our websites is protected.

For example, our websites have electronic security systems in place, including the use of firewalls and data encryption. Depending on the Betterlife Directions businsess unit with which you deal (such as Betterlife Magazine), user identifiers, passwords or other access codes may also be used to control access to your personal information. Please refer to the website of individual business units with which you transact electronically for more information on our website specific privacy policy and security procedures.

When you visit an Betterlife Directions business unit website, our server makes a record of the visits and logs the user's server address, the user's top level domain name, the date an time of visit to the site, the pages accessed and documents downloaded, the previous site visited, and the type of browser used for statistical purposes. During this process no attempt is made to identify users, or their browsing activities, unless a law enforcement agency or a court exercises a valid warrant to inspect the service provider's logs.

Links to other Sites

You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy standard, policies and procedures.

Cookies

Aggegate Corporation may make use of cookies to make our web site perform better. A cookie is a feature built into your web browser that assigns you a user ID. Cookies are used to follow the pattern of movements of web users. Cookies let us know which pages on our web-site are visited, in which order and how often. By themselves, cookies can't be used to discover your identity, they merely identify your computer to our servers when you visit us. If you are unhappy about having a cookie assigned to you, you can set your browser to refuse cookies. Cookies are not used to record any personal information such as your name, address or email address.

Email

We will record your email address or other personal information if you send us a message, subsribe to our mailing list, place an order with us, respond to a prize or product opportunity, request a quote or engage our office or online business, counselling or other services. It will be used for the purpose for which you have provided it to Betterlife Directions, and from time to time we may email you with promotional offers and opportunities to purchase from us, or participate in competitions or surveys.

Security

When you begin to place credit card details on to a page within our web-site, a secure system software call socket security layer (SSL) encrypts all information you input before it is sent to us.

Information by mail

Betterlife Directions appreciates that some people may not wish to submit information via email or the internet. If you do not wish to submit personal information to us through our website or via email, you can write to Customer Service Office, Betterlife Directions Pty Ltd, 53 Main Street, Pialba, QLD 4655 Australia.

General Privacy Issues

Gaining access to your personal information

You can gain access to your personal information. this is subject to some exceptions allowed by law. Factors affecting a right to access include:

• access would pose a serious threat to the life or health of any individual
• access would have an unreasonable impact on the privacy of others
• a frivolous or vexatious request
• the information relates to a commercially sensitive decision making process
• access would be unlawful
• access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function or negotiations with you
• legal dispute resolution proceedings
• where a third party has given us health information about you in confidence
• denying access is required or authorised by or uner law

We will give you reasons if we deny access.

To access this information, you need to email or write to us using the contact details below, or discuss this issue with your Betterlife Directions contact (eg. Therapist, consultant etc.). Search fees, administration fees and/or photocopying fees may be charged to you to make this information available. Certain information may not be accessible for reasons of Privilege or Confidentiality, as subject to the guidelines established by the Australian Psychological Society and the Australian Privacy Act, 1988.

Contact us to get a form requesting access using the contact details below. In some cases we may be able to deal with your request over the telephone or over a counter.

Using Government Identifiers

Although in certain circumstances we are required to collect government identifiers such as your Medicare number or pension card number, we do not use or disclose this information other than when required or authorised by law or unless your have voluntarily consented to disclose this information to any third party.

Dealing with us anonymously

You can deal with us anonymously where it is lawful and practicable to do so. For example, if you enquire about our available services there is no need to provide your personal information.

Your Sensitive Information

Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or crimincal record.

This is subject to some exceptions including:

• the collection is required by law
• when the information is necessary for the establkishment, excercise or defense of a legal claim.

Resolving your privacy issues

If you have any issues you wish to raise with Betterlife Directions, or would like to discuss any issues about our Privacy Policy, then you are able to do so in a number of ways:

• You are always welcome to speak directly with our staff and they will do their best to resolve your issue. If investigation is required we will keep you advised of progress. If staff are unable to resolve the matter, it will be escalated as appropriate to facilitate resolution.
• You can call our Privacy officer on 07 4124 4521 any time between 9am and 5pm Monday to Friday AEST.
• you can put your issue in writing and address it to the address listed below.

Contacting Us

If you have any questions regarding any matters related to your privacy, or if you believe there has been a breach of your privacy, please contact us on:

Mailing address: The Privacy Officer, Betterlife Directions Pty Ltd, Shop 3/53 Main Street, Pialba, QLD 4655 Australia.

Our privacy Hotline: 07 4124 4521 (Australia) or +61 7 4124 4521 (Intl.)

For more information about our Privacy Policy, please call 07 4124 4521 and ask to speak to the Privacy Officer.

For more information about privacy in general, you can visit the Federal Privacy Commissioner's website at www.privacy.gov.au