Privacy Policy - Wisdom Wellbeing New Zealand

Wisdom Wellbeing Pty Limited, when operating in New Zealand, must comply with the New Zealand Privacy Act 2020 (NZ Privacy Act) and the Information Privacy Principles (IPPs).

Wisdom Wellbeing handles personal information in New Zealand in accordance with the NZ Privacy Act and IPPs. In New Zealand, references to the terms “Information Privacy Principles”, “Personal information” and “Sensitive information” have the meanings given under the NZ Privacy Act. References to “you” in this Privacy Policy refer to the individual reading the policy or any individual whose personal information has been collected by Wisdom Wellbeing and/or Peninsula.

Please review this website regularly as this Privacy Policy may change from time to time.

The types of information Wisdom Wellbeing collects will depend on the nature of your dealings with Wisdom Wellbeing. Wisdom Wellbeing will only collect personal information if it is reasonably necessary for one or more of its functions or activities. Wisdom Wellbeing will generally collect personal information about you when you:

• instruct Wisdom Wellbeing to provide advice;

• visit its website;

• provide personal information via Wisdom Wellbeing web form;

• subscribe to a newsletter or to receive Wisdom Wellbeing publications;

• apply for employment with Wisdom Wellbeing;

• attend a seminar provided by Wisdom Wellbeing; and

• engage in business dealings with Wisdom Wellbeing.

If you are a client or a subscriber to Wisdom Wellbeing’s mailing lists or online services, the personal information that will ordinarily be collected about you will include your name, business or residential address, email address and contact numbers.

You have the option of not providing personal information to Wisdom Wellbeing. However, if you decide not to provide the requested information, Wisdom Wellbeing may not be able to provide you with certain services.

Wisdom Wellbeing also collects information that does not, on its own, identify an individual (non-personal information). When you visit Wisdom Wellbeing’s websites, a record of your visit is made with the following information:

• your top level domain name;

• the date and time of your visit;

• the web pages you accessed;

• the documents you downloaded;

• the type of browser you are using;

• your server address; and

• IP address

on a general and aggregate basis, in order to analyse the performance of the site.

This aggregated, non-personal information is collated in order to determine the amount of people who visit Wisdom Wellbeing’s website and the most frequently visited sections of the website. This enables Wisdom Wellbeing to continually update and refine its site. If you use any forms on its website to send an email to someone within Wisdom Wellbeing, a record will also be made of your email address.

When Wisdom Wellbeing combines non-personal information with personal information, Wisdom Wellbeing treats the combined information as personal information.

Wisdom Wellbeing’s websites may contain links to other sites. Wisdom Wellbeing is not responsible for the privacy practices or policies of those sites.

Our website, online services, apps and email messages may use cookies. Cookies help us to better understand user behaviour and tell us which parts of the website people have visited. Wisdom Wellbeing uses cookies to improve the navigational experience of visitors on its website by making it more user-friendly.

If you wish to disable cookies, your browser should allow you to opt out of receiving cookies. If you are not sure whether your browser has this capability, check with your service provider to find out how to disable cookies. Please note that certain features of Wisdom Wellbeing’s website may not be available once cookies are disabled.

Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. Wisdom Wellbeing uses reports provided by Google Analytics to help understand website traffic and webpage usage.

By using this website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

Our website also uses interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to “like” or “share” information from this website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social

Wisdom Wellbeing may collect personal information about you in the ordinary course of its business, including your name, address, date of birth, contact details and occupation. This information may be collected through meetings, face to face interviews, business cards, seminars, telephone calls and from third parties in accordance with the Privacy Act and the NZ Privacy Act.

When Wisdom Wellbeing speaks to you on the phone, calls may be recorded or observed live in the event of an emergency for security, training and quality assurance purposes.

Wisdom Wellbeing will only collect sensitive information about you (e.g. information about your membership of a professional body, race, religion, ethnicity, political opinion or individual health information) with your consent and if the collection is reasonably necessary for one or more of its functions or activities.

Wisdom Wellbeing may use personal information it collects about you for a number of purposes including to:

• compile statistical data and to maintain its database;

• develop/improve its website;

• respond to any email inquiries;

• notify you of any upcoming training or other events;

• provide you with publications;

• manage quality control;

• manage systems administration;

• comply with compliance policies;

• provide you or your employer with advice;

• provide clinical support to guarantee your safety;

• direct marketing;

• receive services from you or your employer; and

• assist with employment or to consider suitability of employment.

Wisdom Wellbeing will not use or disclose your personal information for any purpose which is not related (or in the case of sensitive information, directly related) to the above purposes without your consent, or unless otherwise authorised, required or permitted under Australian and New Zealand law or regulation.

Wisdom Wellbeing will not use or disclose personal information it holds for direct marketing purposes to any third party outside of Wisdom Wellbeing unless you consent to its use for this purpose. If you no longer wish to receive information about Wisdom Wellbeing’s services, or other marketing communications, please send an email to Wisdom Wellbeing’s marketing team at marketing@peninsula-au.com advising that you do not wish to receive such information.

From time to time, we may also use your information to tell you about products or services provided by Wisdom Wellbeing that we think you might be interested in.

To do this, Wisdom Wellbeing may contact you by:

• Email;

• Phone;

• SMS;

• Social media;

• Advertising through our apps, websites, or third-party websites; and

• Mail.

Wisdom Wellbeing may use or disclose personal information it holds for direct marketing purposes to any Group Member. If you do not consent to this and / or you don’t want to receive direct marketing message or want to change your contact preferences, please opt out by:

• Clicking on the "unsubscribe" or "opt out" link provided;

• Emailing: marketing@wisdomwellbeing.au

Wisdom Wellbeing may disclose your personal information in the following ways:

• On a confidential basis to external service providers that provide services such as financial,

administrative services, emergency services, GP and local authorities in connection with the operation of its business;

• To Group Members for the purposes of Direct Marketing;

• To any person (where necessary) in connection with its services, such as to regulatory authorities,

partners or advisors; or

• To related entities of Wisdom Wellbeing overseas, including in the UK, Canada and New Zealand, but in all such cases in accordance with the APPs and IPPs.

Examples of services provided by external service providers include mailing houses, payment processors, archiving services, research organisations and consultants who conduct research on behalf of Wisdom Wellbeing so it can better meet the needs of clients and staff.

If Wisdom Wellbeing engages external service providers, it will take reasonable steps to ensure those entities comply with their obligations under the APPs and IPPs when they handle your personal information. Wisdom Wellbeing will also ensure external service providers are only authorised to use personal information for the limited purposes specified in Wisdom Wellbeing’s agreement with them.

Wisdom Wellbeing will also take reasonable steps to ensure that any overseas related entities or service providers comply with the applicable sections of the APPs and IPPs in relation to how your personal information is held, managed and accessed

The Group may collect the following personal information about an individual employed (Employee) by a client (Employer) of the Group member:

• name and address; • email address • date of birth;

This information may include sensitive information (including information relating to an employee’s health or ethnic origin).

Any information about Employees will be collected and stored at the request of, and with the consent of, the Group’s clients. Clients may collect, store, use and disclose this information for the purpose of staff administration and management, equal opportunities monitoring and other employment related matters. The Group’s staff may also use information collected in the provision of its services. An Employee’s personal information will only be used for purposes related to (or in the case of sensitive information, directly related to) providing the services, or as otherwise authorised, required or permitted under law, or for another purpose to which the employee consents.

The Group will not disclose any Employee’s personal information to third parties without consent from the Employee, unless such disclosure is to an appropriate authority, government body, regulator, law enforcement agency or other party required, authorised or permitted under law. Employees may request copies of their personal information, request amendments to their information and make a complaint in accordance with this Privacy Policy.

If you wish to obtain access to any personal information that Wisdom Wellbeing has collected about you, please make a request in writing to Wisdom Wellbeing’s Compliance and Risk Team compliance.risk@peninsula-au.com. A reasonable fee may apply for the provision of this information (ordinarily, an electronic print out or photocopy). Identification will be requested for security purposes.

Wisdom Wellbeing will take reasonable steps to make sure that any personal information it collects, uses or discloses is accurate, complete and up-to-date. If you believe that any information held by Wisdom Wellbeing is inaccurate, incomplete, out of date, irrelevant or misleading, please contact Wisdom Wellbeing’s Compliance and Risk Team compliance.risk@peninsula-au.com.

Request for access and/or amendments will be responded to within a reasonable period of time in accordance with the APPs and IPPs. Wisdom Wellbeing will notify the Employer if Wisdom Wellbeing receives a request from an Employee. Wisdom Wellbeing may refuse a request for access or amendment to personal information in the circumstances outlined in the APPs and IPPs. If access is refused, Wisdom Wellbeing will provide you with a written reason for the refusal.

If you have any complaints about Wisdom Wellbeing’s dealings with your personal information, including any breaches by Wisdom Wellbeing of the APPs and IPPs, please email Wisdom Wellbeing’s Compliance and Risk Team with:

(a) details of your complaint including relevant dates and names of third parties (if any); and

(b) provide any relevant documents or correspondence.

Wisdom Wellbeing will acknowledge receipt of your complaint within two days and investigate the issue. Wisdom Wellbeing will advise you in writing of the outcome of the investigation within a reasonable period of time in accordance with the APPs and IPPs. If you are not satisfied with the outcome, Wisdom Wellbeing will advise you of further options including, if appropriate, review by the Privacy Commissioner within the Office of the Australian Information Commissioner (see http://www.oaic.gov.au/ for further information) or the New Zealand Privacy Commissioner (see http://www.privacy.org.nz/ for further information).

Wisdom Wellbeing takes all reasonable steps to ensure that personal information is kept secure and protected against unauthorised access, modification or disclosure and from misuse, interference and loss.

Any information which Wisdom Wellbeing holds is stored on secure servers, either in Australia and/or overseas (UK, Canada and New Zealand), that are protected in controlled facilities. Only certain authorised employees of Wisdom Wellbeing and/or contractors who provide services in relation to its information systems will have access to the secure servers.

Although Wisdom Wellbeing has put in place certain checks and measures in relation to system security, Wisdom Wellbeing cannot guarantee that data transmitted over the internet will be 100% secure. Wisdom Wellbeing will not be responsible for the security of information you send to, or receive from Wisdom Wellbeing, over the internet.

In the event of a data breach, Wisdom Wellbeing is committed to complying with the requirements of all the Privacy Laws and where required, the provisions of the General Data Protection Regulation.

Wisdom Wellbeing retains information you provide to it and information which it collects about you, including personal information, for as long as Wisdom Wellbeing continues to provide services to you and specifically until such time as you request Wisdom Wellbeing to delete your personal information. Wisdom Wellbeing will retain all information relating to services provided to clients for a minimum of seven years after the date that a client ceases to use its services.

During registration with the Wisdom App, we collect your name, gender, phone number, date of birth and email address. This will enable Wisdom Wellbeing to administer the Wisdom app. When registering for the Wisdom app, users are informed about our Terms and Conditions and Privacy Policy at the point of registration and no data is stored until the user agrees to the Terms and Conditions.

The Wisdom app also allows users to submit additional data through the Enquiry Form or Live Chat functions. This will be sent directly to wisdom Wellbeing for the purpose of administering the requested services. This data is collected for the purpose of providing the services and will then be securely stored in our CRM and retained in line with our retention policy.

To ensure functionality and user administration the organisation that provides you with access to the app (such as your employer) and the app developer, have access to limited app usage data. This allows them to see your registration details in order to confirm that the intended users are able to access the resource. Neither will be able to see how you have used the app or what content has been accessed.

Wisdom does not use tracking software to collect data about the users or their online actions. The information contained in the ‘Health Trackers’ feature of the app (i.e. user’s steps, sleep, weight etc.) is retrieved from Apple Health application for iOS and Google Fit for Android devices and displayed within Wisdom, on the Health Hub & Health tracker screens. Users must give the device permission before the app can access this data from the Apple Health or Google Fit. Wisdom's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Other permissions required in order to access certain features are: A. permission to send the user push notifications

B. permission to access camera, camera roll and saved pictures to upload a profile picture to the app C. permission to access the camera for biometric login.

Wisdom Wellbeing will not share your personal data with any third parties without your consent. Wisdom Wellbeing do, however, collect anonymised usage information and statistics for the purposes of monitoring app and website use. This helps us develop our service and show utilisation to the contract holder.

If you have any questions about this Privacy Policy or Peninsula’s privacy practices, please contact Peninsula’s Compliance and Risk Team (details below):

Compliance and Risk Team E: compliance.risk@peninsula-au.com

Alternatively, you can write to us at:

Peninsula, Compliance and Risk Team

Level 6, 180 Thomas Street

Haymarket NSW 2000

Australia