This Privacy Policy applies to Bethany Alice Phelan trading as Calm Sanctuary ABN 59 133 824 693 (“we”, “us” and “our”) and sets out the manner in which we collect, store, manage, use and disclose personal information. 

We take the handling of your personal information and privacy very seriously and do so in accordance with the Australian Privacy Principles ("APPs"), contained within the Privacy Act 1988 (Cth) ("Privacy Act").

1.              TYPES OF PERSONAL INFORMATION WE COLLECT

1.1           The Privacy Act defines 'personal information' to mean information or an opinion about an identified individual, or an individual who is reasonably identifiable. 

1.2           We commonly collect the following kinds of personal information about you:

·       Name, date of birth and occupation;

·       Business name, company name, ACN and ABN;

·       Information about you or your business;

·       Contact information such as personal address, business address, postal address, email address, telephone number, emergency contacts, doctor’s contact details;

·       Government identifiers including Medicare details;

·       Payment information;

·       Any information or documents which are uploaded to the Calm Sanctuary platform;

·       Information about your interactions on or via the Calm Sanctuary platform;

·       Information you provide via free text inputs on or via the Calm Sanctuary platform;

·       Your preferences;

·       Your relationship to other users of Calm Sanctuary;

·       General information such as gender, service history, details of services enquired about and feedback;

·       Your IP address, device type, website visitor analytics, Google Analytics, advertising data and 'cookies';

·       Information about you, which is held by third parties, where you have provided your separate consent to such collection, such as information that is or was held by the National Disability Insurance Agency;

·       Other personal information that may be required in order to facilitate your dealings with Calm Sanctuary; and

·       ‘health information’ as defined under the Privacy Act 1988 (Cth), such as information about your health or disability, doctors or other health professionals you have seen or health services you have received.

It is uncommon that most of this information would be collected, and this depends on the specific nature of our interactions.

2.              COLLECTION OF PERSONAL INFORMATION

2.1           The above information is:

2.1.1      collected in person and online; and

2.1.2      only collected, used and disclosed by us where reasonably necessary for us to do so to perform our services.

2.2           The information we collect is necessary for us to fulfil our services. Where practicable, we will collect personal information directly from you.

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3.              USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION

3.1           We collect and use personal information for the following purposes:

·       To provide you with our communications and engage with you;

·       To identify you to establish and maintain a record of you for our services;

·       To assess, diagnose and treat psychological illnesses;

·       To be proactive in your health care needs;

·       To store information necessary for relevant emergency contacts and treating teams;

·       To store information necessary for Medicare and other funding rebates;

·       To collect payment for our services;

·       For audits and accreditation of our services;

·       To provide an adequate standard of mental health care required in the circumstances;

·       To provide you with marketing material and promotional messages relevant to you;

·       To obtain the services of third-party service providers as part of providing our services to you;

·       To manage and improve our policies (including in relation to occupational health and safety), employment standards, staff training and general customer experience; and

·       Where we are otherwise required or authorised to do so by law.

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3.2           Our main purpose for collecting, storing, using and disclosing personal information is to:

·       undertake our business operations and to enable us to efficiently supply our services;

·       respond to enquiries and other related customer service purposes; and

·       undertake marketing and promotional initiatives.

3.3          Whilst conducting our business, it may from time to time be necessary for us to share information about you. This includes:

•  For the purposes for which we have advised that we are collecting it, and for related purposes that the individual would reasonably expect,

•  Where we have the consent of the individual to do so,

•  As required by law, or

•  Under other circumstances where permitted under the Act.

In the course of our business activities, we may need to disclose some of your personal information to relevant staff, for instance, your contact details and Medicare number are accessible to the administrative team.

4.              REQUESTING ACCESS TO OR CORRECTING YOUR PERSONAL INFORMATION

4.1           You may request access to the personal information we hold about you at any time by using the contact details set out below:

Email:              admin@calmsanctuary.com.au

Phone:            *****

Post:               Ground floor, 470 St Kilda Road Melbourne Vic 3004

4.2           Please note we will need to verify your identity before providing you with any requested information. This includes any request to amend or delete our records.

4.3           If for whatever reason we cannot provide you with access to the requested information (for example if the information requested is subject to legal privilege), we will provide you with written correspondence setting out (unless we are legally prevented from doing so) the reasons for our refusal and the complaint options available to you.

4.4           All requests for personal information will be responded to as soon as possible and within a reasonable timeframe unless there are extenuating circumstances. If that is the case, we will advise you of the reasons in writing as soon as reasonably possible. Calm Sanctuary will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information

4.5           We seek to ensure that the personal information we hold is accurate, up-to-date and complete. If you believe that any personal information we hold including any you have provided to us directly is incorrect, out of date, misleading or provided unlawfully, you may request that the information be corrected by using the above contact details. Where appropriate, we will ensure that all reasonable steps are taken make applicable corrections within a reasonable timeframe.

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5.              SECURITY 

5.1           Your personal information may be stored either as hard copies or electronically, and we take reasonable steps to protected that information from misuse or unauthorised access.

5.2           Our electronic databases, information technology systems, physical stores, warehouses, and all other business premises all have sufficient levels of security measures implemented such as SSL encryption methods, cookies on our website, our practice management software and the use of Stripe for storage of financial information.

6.              EXTERNAL LINKS

6.1           Any external links found on our website are to websites which are not under our control. We recommend you review the privacy policies of those websites before using them and before disclosing your personal information on those websites.

7.              COOKIE POLICY

7.1           In compliance with Australian privacy law, we use various digital tools including cookies, web pixels, and similar technologies on our website. These tools collect data that helps us understand how you use our website, ensure security, and improve user experience.

7.2           Cookies are small files placed by a website onto your device to store information, aiding in your recognition on subsequent visits and remembering your user preferences. They enhance your browsing experience and allow our website to operate efficiently. These are split into two categories:

7.2.1      First-Party Cookies: Managed through your browser's settings, these cookies are directly from our site. Instructions to manage them are typically found under 'Help' or 'Settings' in your browser. Disabling cookies might limit your access to certain parts of our website.

7.2.2      Third-Party Cookies: For managing cookies from external advertising networks and entities, you may adjust your settings or withdraw consent through our website.

7.3           Our website utilises cookies and pixels for the following specific functionalities:

7.3.1      Strictly Necessary: These are essential cookies and pixels required for the basic operation and functionality of our website. They respond to your actions which are service requests, like privacy settings, browsing or filter preferences, adding products to a cart or filling out forms. Blocking these may affect the functionality of the website.

7.3.2      Performance: Cookies and pixels in this category function in a manner which permits us track the number of visits and visitors’ traffic patterns. This data allows us to optimise the performance of our website and is essential for creating analytical reports which allow us to understand site usage, popularity of certain pages and products, user navigation patterns, and any errors or bugs that may arise.

7.3.3      Functional: These enhance the user experience by providing personalised functionality and third-party g integrated into our website. Disabling these may reduce the functionality of certain features and affect user experience.

7.3.4      Advertising: Employed by us or our partners, these cookies and pixels are designed to gather information about your interests, tailoring advertising to your preferences, and can engage with you through specific messaging, such as reminders for abandoned shopping carts or stock status alerts.

7.3.5      Precise Location Data: Subject to your consent, we may activate precise location tracking features on your device to collect detailed location data. This data is used to confirm your device location and customise content and advertising geographically. This is primarily used to determine the language and currency displayed on the website based on the user’s location.

8.              EUROPEAN USERS

8.1           Our Privacy Policy aims to comply fully with the General Data Protection Regulation (GDPR) and we are committed to protecting the privacy and security of users’ personal data in the European Economic Area. This includes but is not limited to the following:

8.1.1      Right to Correction and Erasure: users have the right to request that we correct or delete their personal data if:

·       The data is no longer necessary for the purpose for which it was originally collected.

·       You withdraw consent for the data’s processing.

·       The data was unlawfully collected.

·       This right is an extension of the 'right to be forgotten'.

8.1.2      Right to Portability:

·       Users may request their personal data in a structured, commonly used, and machine-readable format.

·       Users have the right to transfer their data to another entity without interference from the original data collector.

8.1.3      Right to Object to Processing: At any time, users may object to the processing of their personal data.

8.1.4      Destruction or De-Identification of Data: We aim to responsibly destroy or anonymise personal information that is no longer required for the purpose it was collected for.

8.1.5      Access to Personal Information: Users are provided access to their personal data and, upon request, supplied in the format preferred by the user.

8.2           We process your personal data with your consent. If consent isn't legally necessary, our processing is grounded in the legitimate interest of enhancing our business and providing you with customised, pertinent content.

8.3           Should we need to move your personal data from Europe to a non-European country, we will implement extra measures as required by European data protection legislation to ensure its security.

9.              ENQUIRIES AND COMPLAINTS

9.1           If you have a question relating any matter raised in this privacy policy or wish to make a complaint, please contact us using the contact options outlined in paragraph 4.1, but preferably in writing.

9.2           Please ensure that all written communication to us includes your full name, preferred contact details and as much information regarding your enquiry or complaint as possible.

9.3           We will ensure that all reasonable steps are taken to investigate your complaint promptly and will respond to you within a reasonable timeframe (generally within 30 days), in accordance with our legal obligations.

9.4           You also have the right to contact the Office of the Australian Information Commissioner on 1300 363 992 or via email at enquiries@oaic.gov.au.

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We may review this Privacy Policy and make changes to it from time to time for any reason on our website without notice to you. For more information visit www.oaic.gov.au.

​This policy was last updated in May 2024 and may be updated at any time.