Keystone Privacy Policy

 

This policy is in effect as of v1.1, 21 May 2018.

 

The privacy policy gets updated from time to time. This update looks to our growing international user base, and to ensure that we continue to be transparent about our practices. These updates also address the new requirements under the European Union (EU) data protection law called the General Data Protection Regulation (GDPR), which goes into effect on May 25, 2018.

Your privacy is important to us, and so is being transparent about how we collect, use and share information about you.  This policy is intended to help you understand:

1.    What information we collect about you

2.    How we use information we collect

3.    How we share information we collect

4.    How we protect your information

5.    Managing your information and Privacy Settings

 

This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with Keystone Health and Fitness Pty Ltd. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information (PII).   This policy also explains your choices about how we use information about you.  Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you.

If you decide that you do not agree with this policy, it is important that you do not access or use our Services or interact with any other aspect of our business.

When we refer to “Keystone”, “we”, or “us” in this policy we mean the Keystone Platform, Keystone Website, Keystone Coaching Portal and Keystone App (collectively “Services” or “Keystone Services”) which are owned and operated by Keystone Health and Fitness Pty Ltd.

When we refer to “you” or “they” in this policy we mean anyone that interacts with the Keystone Services including the Coach, Gym, member, client and/or end user.

Over time this policy may require updating. We will notify you when changes occur via email. You acknowledge and agree that it is your responsibility to review this policy periodically to familiarise yourself with any modifications. Your continued use of this site after such modifications will constitute acknowledgment and agreement of the modified terms and conditions.

 

What information we collect about you

Keystone Services collect information to operate our business and provide you with Health and Fitness solutions.    We collect this information from the Coach and the End User, their client or member. 

Information you provide to us

Content you provide through our website:  When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, credit card information or other details to help you with your experience.  

Content you provide through our products:  When using our Services and Products, we collect and store content that you create, send, receive and share.  This content includes any information about you that you may choose to include and provide.  For example, the End User provides their feelings, body metrics, nutrition and training information when you use Keystone App.    The Coach provides workouts and coaching to their clients and invites their clients to use Keystone App by providing the client’s name and email address.

Account and Profile information

We collect information about you when you register for an account, create or modify your profile, set preferences, sign up for or make purchases through the Services.  We collect certain payment and billing information you provide us in order to register you for certain Services.

Information we collect automatically when you use our Services

We collect information about you when you use our Services including browsing our websites, providing us with feedback on our products or services and taking certain actions within the Services.

Use of Cookies and other Tracking Technologies

Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognise your browser and capture and remember certain information. For instance, we use cookies to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.  

We may also use trusted third-party services that track this information on our behalf. We honour Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

We do not allow third-party behavioural tracking for advertising purposes.

Your use of the Services

We keep track of certain information about you when you visit and interact with any of our Services.

Device and Connection information

We collect information about your computer, phone, tablet or other devices you use to access the Services. 
 

 

How we use information we collect

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us.   

We may use the information we collect from you in the following ways:

  • To operate our business and improve our products to better serve you.
  • To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
  • To allow us to better service you in responding to your customer service requests.
  • To administer a contest, promotion, survey or another site feature.
  • To quickly process your transactions.
  • To ask for ratings and reviews of services or products
  • To communicate with you about the Services and to follow up after correspondence (live chat, email or phone inquiries)
  • To protect our legitimate business interests and legal rights

Inviting clients to use Keystone

When a client is invited to use Keystone Services by their Coach, we require the client’s name and email address to send the invitation to download the App. This PII provided is only used to directly link the client to the coach and is not used or disclosed to any other party. Additionally the client is free to unsubscribe or not accept an invitation.

Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless legally required to do so. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety.

Non-personally identifiable information may be provided to other parties for marketing, advertising, or other uses.

 EEA users

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws.   The legal bases depend on the Services you use and how you use them.  We collect and use your information only where:

  • We need it to provide you the Services, including to operate the Services, provide customer support and personalised features and to protect the safety and security of the Services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.

You may choose not to provide Keystone with your Personal Data, however if you choose not to provide your Personal Data you may not be able to enjoy the full range of services.  If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. 

Where we are using your information because we or your Coach have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

 

How we share information we collect

Keystone services are a coaching platform designed for your wellness and fitness benefit. 

By accepting the invitation from your Coach to use Keystone services you agree to sharing the personal information you provide within the Keystone App directly with your Coach. 

You have a separate agreement with your Coach for the provision of coaching and Keystone Services are not responsible for how they use your information.    The Coach is bound by Keystone terms of use which prohibits the unlawful use, disclosure or access to your Personal Data.

Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites, nor do we have any control over the information you share with them. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

 

 

How we protect your information

Data retention

For the purposes of applicable data protection laws, Keystone is the controller of the Personal data you provide to us (“Data Controller”).  As a Data Controller, we process the Personal Data we maintain about you in accordance with this Privacy Policy.  

Keystone Services will retain your Personal Data for as long as you maintain an Account or as needed to provide you the Services.  We will also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Keystone Services are committed to protecting the security of your Personal Data. We use regular Malware Scanning and our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through a payment gateway provider and are not stored or processed on our servers.

We also recommend that you take additional measures to protect yourself and your information, such as installing anti-virus software, closing browsers after use, keeping confidential your login credentials and passwords, and making sure that you regularly update software and apps you have downloaded to ensure you have enabled the latest security features on your devices.

 

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

 

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

  • We will notify you via email within 7 business days.

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

 

 

Managing your information and Privacy Settings

We provide you several ways to manage and be informed about your privacy settings.

This Privacy Policy will be available on our home page or as a minimum, on the first significant page after entering our website.  Our Privacy Policy link includes the word 'Privacy' and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes on our Privacy Policy Page, and you can change your personal information:

  • By emailing us, or
  • By chatting with us or sending us a support ticket

 

Children

We do not specifically market to children under the age of 13 years old and we do not knowingly collect personal Data from children under 13.   If we become aware that a child under 13 has provided us with Personal Data without parental consent, we will take steps to remove the information and terminate the child’s account.

Contacting Us

If you have any questions or comments about these our Privacy Policy as outlined above, you can contact us at:

info[at]keystone.fit

Keystone Health and Fitness Pty Ltd
146 Thistlethwaite Street
South Melbourne, Victoria 3205
Australia


 

PRIVACY History

Version 1.0