Marketing Privacy Policy

MARKETING PRIVACY POLICY

Wimp 2 Warrior Limited ACN 163 057 565 (“W2W”), its subsidiaries and affiliates are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.

This document (“Marketing Privacy Policy”) sets out our main policies for managing your personal information.

In this Marketing Privacy Policy, “we“, “us” and “our” refers to W2W and “you” refers to any individual about whom we collect personal information.

ABOUT W2W

W2W is a high growth business providing technology enabled Combat Sports fitness training In-Gym and At-Home. W2W sits at the intersection of the world’ fastest growing sport (MMA) and the high growth fitness market.

WHAT INFORMATION DOES W2W COLLECT ABOUT YOU?

Members and prospective members

When you enquire about our services or when you subscribe or become a member of W2W, a record is made which includes your personal information. The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will normally include:

  • your age;
  • your fitness statistics which you provide to us;
  • details of the products and services (such as membership options) you have purchased from us or which you have enquired about;
  • your login details and passwords;
  • any additional information relating to you that you provide to us directly through our websites or via email or in person; and
  • any additional personal information you provide to us, or authorise us to collect, as part of your interaction or membership with W2W.

Other individuals

W2W may collect personal information about other individuals who are not members of W2W. This includes customers and members of the public who participate in events we are involved with; individual service providers and contractors to W2W; and other individuals who interact with W2W on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with W2W. Generally, it would include name, contact details, and information regarding our interactions and transactions with you.

If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.

You can always decline to give W2W any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.

Your sensitive information

W2W may collect and process your sensitive information or special category data, such as your health information, generally with your express consent and only as reasonably necessary in order for us to provide our services to you. We may also collect such information about you in an emergency or otherwise with your consent or in accordance with applicable laws.

What happens if you don’t provide your personal information?

You can always decline to give W2W any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested or we may not be able to do business with you effectively. If you have any concerns about personal information we have requested, please let us know.

HOW AND WHY DOES W2W COLLECT AND USE YOUR PERSONAL INFORMATION?

W2W collects personal information reasonably necessary to carry out our business, to assess and manage our members’ needs, and provide our services to you. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing member relationships.

The purposes for which W2W usually collects and uses personal information depends on the nature of your interaction with us, but may include:

  • to obtain opinions or comments about products and/or services from members;
  • to fulfil obligations under an agreement you may have with us;
  • to provide information about products, services and/or special offers to members;
  • to record statistical data for marketing analysis from members;
  • responding to requests for information and other general inquiries;
  • managing, planning, advertising and administering programs, events, competitions and performances;
  • researching, developing and expanding our facilities and services;
  • informing you of our activities, events, facilities and services; and
  • responding to enquires and complaints.

In addition, some of your personal information may be used for other business purposes. Examples of the types of uses are set out below:

 

  • to improve the relevance of marketing messages we may send you (which you can opt out of).
  • for our reasonable commercial purposes (including quality control and administration and assisting us to develop new and improved products and services);
  • to follow up with you after you request information to see if we can provide any further assistance;
  • to comply with any requirement of any applicable law or regulation, whether originating from Australia or elsewhere;
  • to fulfil our obligations under any reporting agreement entered into with any authority from time to time;
  • to check your instructions to us, to analyse, assess and improve our services to members; and
  • to share information with relevant third parties in the context of a sale or potential sale of a relevant part of our business, subject always to confidentiality obligations.

 

W2W generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:

  • our affiliated and related companies; and
  • third party suppliers and contractors who assist us to operate our business.

W2W also collects and uses personal information for market research purposes and to innovate our delivery of products and services.

 

We have a legitimate interest in using your information in the ways listed above. In some cases it will be lawful for us to collect and use your personal information.

HOW DO WE HOLD INFORMATION?

W2W stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia and the United States). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

W2W maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT BY W2W

We will only keep the personal information we collect about you for as long as is necessary for the purposes set out in this Marketing Privacy Policy or as required to comply with any legal obligations to which we are subject. We take steps to destroy or de-identify information that we no longer require or as required by an applicable law.

DOES W2W USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?

W2W may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you or as otherwise permitted under applicable privacy laws.

This means under certain privacy laws we do not always need your consent to send you marketing communications such as our member newsletter. However, where consent is required under applicable privacy laws, we will ask for this consent separately and clearly. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below or using the opt-out functionality contained in the electronic message.

If you opt-out of receiving marketing material from us, W2W may still contact you in relation to its ongoing relationship with you.

HOW DOES W2W USE AND DISCLOSE PERSONAL INFORMATION?

For members

The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers (including a coach who is a contractor) where this is relevant to our services.

For customers and participants

If you are a customer or participant in an event, we may disclose your personal information to venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.

Disclosure to contractors and other service providers

W2W may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research. Personal information may also be shared between related and affiliated companies of W2W, located in Australia and overseas. Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.

Other uses and disclosures

We may use and disclose your personal information for other purposes explained at the time of collection (such as in a specific privacy collection statement or notice) or otherwise as set out in this Marketing Privacy Policy.

DOES W2W DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?

W2W is a global organisation and works with members, service providers, sponsors and commercial interests across the globe. It is likely that your personal information will be disclosed to overseas recipients including service providers who may handle, process or store your personal information on our behalf.

It is likely that your personal information will be transferred outside of the jurisdiction it was collected. We only ever disclose your personal information outside the jurisdiction it was collected where we are permitted to do so under applicable privacy laws. Generally this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws.

 

HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?

You are entitled to access your personal information held by W2W on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below. We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. After receiving a request from you, we will take reasonable steps to correct your information. We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles.

WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?

You may contact W2W at any time if you have any questions or concerns about this Marketing Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

If you are not satisfied with our response to your complaint, or you consider that W2W may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website

HOW CHANGES ARE MADE TO THIS MARKETING PRIVACY POLICY?

W2W may amend this Marketing Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes. We also try to let you know about major changes to our Marketing Privacy Policy (for example by putting a notice up on our website).

HOW CAN YOU CONTACT W2W?
The contact details for W2W are:
Email: [email protected]
Postal: Level 1, Suite 1 29-33 The Corso Manly, NSW, 2095