Strength By Numbers
Thank you for using SBN Technology Pty Ltd (ACN 624 009 598) (Strength By Numbers, us or we). We provide a service that allows users to assess the physical strength and movement of their clients.
Your privacy is important to us and we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act), which includes the Australian Privacy Principles (APPs) and any related privacy codes.
This Policy outlines how we collect, use, disclose and store your personal information and lets you know how you can access that information. This Policy applies to our obligations when handling information in Australia.
Please read this Policy carefully and contact us using the details below if you have questions.
By providing personal information, you consent to us collecting, using, storing and disclosing your personal information in accordance with this Policy or as required or permitted by law.
If you continue using our services, then we will treat your use as your consent to us handling your personal information in accordance with this Policy.
The type of personal information we collect depends on the circumstances of its collection and the nature of your dealings with us.
If you use our services or register an account with us, this information may include:
If you are a prospective employee or independent contractor applying to work with Strength By Numbers, we may collect the following information:
For general users that have may not subscribed to our service but interact with us, we may collect information when you connect with us or use our website. This may include information:
We collect some sensitive information from individuals. This may include examination data, test results and previous injury history including the type of injury and date of the injury. If you consent to providing us with this information, we will only use it for the following purposes relating to our provision of services and to enable you to use our website.
You may choose to not identify yourself or use a pseudonym when you contact us, such as if you lodge a complaint. However, if you choose not to provide information as requested, we may not be able to service your needs. For example, it will not be possible for us to provide you with our service if you want to remain anonymous or use a pseudonym.
We sometimes receive unsolicited personal information. In circumstances where we receive unsolicited personal information we will usually destroy or de-identify the information as soon as practicable if it is lawful and reasonable to do so unless the unsolicited personal information is reasonably necessary for, or directly related to, our functions or activities.
We collect your personal information primarily to provide you with our service of assessing individuals’ physical strength and movement and to enable your use of our services.
Some ways we use your personal information are:
In relation to the personal information of contractors or prospective staff members, we collect personal information for purposes including to:
For our customers, we may use the information we collect to better understand our users and gain insights into customer behaviour, and to facilitate our provision of our products and services to our customers.
You give it to us
We collect personal information directly from you when you:
We collect it
We may also collect your personal information from third parties including:
We endeavour to only ask for your personal information if it is reasonably necessary for us to carry out our business activities and will generally obtain consent from the owner of the personal information to collect their personal information. Consent will usually be provided in writing; however, sometimes it may be provided orally or may be implied through a person’s conduct. We endeavour to only ask for your personal information if it is reasonably necessary for the activities that you are seeking to be involved in.
We may disclose your personal information to the following third parties:
We may also disclose your personal information if we are required, authorised or permitted by law.
We may send information to third parties that are located outside of Australia. These third parties are located in the locations set out in our Sub-processor List, although this list may change from time to time. Disclosure is made to the extent that it is necessary to perform our functions or activities.
From time to time, and in support of our future development and growth, we may use your personal information to contact you to promote and market our products and services. We may also share your personal information with our commercial and business partners for marketing purposes.
You can opt-out from being contacted for direct marketing purposes by contacting us at [email protected] or by using the unsubscribe facility included in each direct marketing communication we send. Once we receive a request to opt out from receiving marketing information, we will stop sending such information within a reasonable amount of time.
We take all reasonable steps to protect personal information under our control from misuse, interference, loss and from unauthorised access, modification or disclosure. We hold your personal information electronically in secure databases operated by our third-party service providers set out in our Sub-processor List.
We protect the personal information we hold by implementing the appropriate physical, electronic, and organisational measures, including pseudonymisation of customer and end user data, https encryption of data transmitted through the internet to protect against eavesdropping and tampering, employee access restriction, regular technical assessments and updates of the Strength By Numbers systems, systems and network monitoring for suspicious or irregular behaviour or use of our service, staff education and training in strong security practices, physical security measures and cyber security measures which we regularly review and update.
While we take reasonable steps to ensure your personal information is protected from loss, misuse and unauthorised access, modification or disclosure, security measures over the internet can never be guaranteed.
We encourage you to play an important role in keeping your personal information secure, by maintaining the confidentiality of any passwords and account details used to access our services.
You are able to request access to personal information we hold about you. If you would like to access your personal information, please contact us using the details below. In certain circumstances, we may not be able to give you access to your personal information in which case we will write to you to explain why we cannot comply with your request.
We try to ensure any personal information we hold about you is accurate, up-to-date, complete and relevant. If you believe the personal information we hold about you should be updated, please contact us using the details below and we will take reasonable steps to ensure it is corrected if appropriate.
We destroy or de-identify personal information when we no longer need it, unless we are otherwise required or authorised by law to retain the information.
If you believe your privacy has been breached or you have a complaint about our handling of your personal information, please contact us using the details below.
We take privacy complaints seriously. If you make a complaint, we will respond within 5 days to acknowledge your complaint. We will try to resolve your complaint within 30 days. When this is not reasonably possible, we will contact you within that time to let you know how long we will take to resolve your complaint.
We will investigate your complaint and write to you to explain our decision as soon as practicable.
If you are not satisfied with our decision, you can refer your complaint to the Office of the Australian Information Commissioner by phone on 1300 363 992 or online at www.oaic.gov.au.
We may, from time to time, amend this Policy. Any changes to this Policy will be effective immediately upon the posting of the revised Policy on our website. By continuing to use the services following any changes, you will be deemed to have agreed to such changes.
All questions or queries about this Policy and complaints should be directed to:
Email: [email protected]
This Policy was last updated in July 2023
SBN Technology Pty Ltd (collectively, Strength By Numbers, we, us, our) is committed to protecting your privacy. We have prepared this GDPR Privacy Notice to describe to you our practices regarding personal information we collect from users of our services, including our website at www.strengthbynumbers.com, and all other services provided by Strength By Numbers (Services).
Sometimes, we also handle the information of European Union (EU) and United Kingdom (UK) citizens or share data with other organisations which do so or provide services to individuals located in the EU and UK. To the extent that we do so for individuals:
The processing of Personal Information will always be in line with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth), the EU GDPR and UK GDPR, and in accordance with country-specific data protection regulations and other applicable regulations to Strength By Numbers.
We have implemented a number of technical and organisational measures to ensure the most complete protection of Personal Information processed through the Services.
The EU GDPR and UK GDPR provide you with eight key rights, being the right to:
This Privacy Notice sets out, among other things, how you can exercise these rights when dealing with Strength By Numbers.
Where we rely on your consent as the lawful basis to process your data under the GDPR regime applicable to you we will always ask for you to positively affirm your acceptance. By clicking to accept this Privacy Notice, you acknowledge and agree to be bound by this Privacy Notice.
We note that all contact or other data forms where consent is required to be given by you include no pre-checked checkboxes so that you are able to freely, affirmatively opt-in. We will also provide you with notice on the Services specifically detailing what it is that you are consenting to in clear and plain language as well ensuring that each matter that requires consent is clearly distinguishable.
For all areas of the Services where consent is given it is just as easily able to be withdrawn through the appropriate account settings on the Services or by contacting us at the details provided below.
If you believe that consent has not been given freely or in breach of the terms of this Privacy Notice, please contact us.
We will only collect Personal Information from you if it is reasonably necessary for one or more of our functions or activities.
Personal Information means any information that allows someone to identify you, including, for example, your name, telephone number, e-mail address, date of birth, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
You need to create an account with us to use some of our Services.
During your account registration and use of the Services, you may enter your details on different forms or provide us with additional content.
We may collect Personal Information from you, such as:
This data is used to enable us to identify and verify you and provide you with support, services, mailings, sales and marketing actions. Certain functionality of the Services requires your Personal Information to function properly.
When you create or share content, or upload content such as notes, physical assessment results, photos, meta data (geographic tags) we may also collect this data.
The legal basis for this processing is based on:
If you are a customer or another individual who makes payment to us, we may collect information when we process that data. When you make a payment, we (or our third-party service provider) will collect all information necessary to complete the transaction, including:
The Personal Information we collect will be the data that you input in any payment area on the Services.
The legal basis for this processing is based on:
This Personal Information is needed to enable us to process your payment for our Services.
If you provide us feedback or contact us via e-mail, or other means including by phone call or by contracting with us, we will collect your name and e-mail address, as well as any other content included in the e-mail or conversation, in order to send you a reply. We will store and process your communications and information as needed. We may also collect contact information if you choose to upload, sync or import it from a device.
The legal basis for this processing is based on:
By submitting a form or contacting us such Personal Information is transmitted on a voluntary basis and you consent to its collection.
When you use the Services, you may have the ability to subscribe to our newsletters or other forms. We may collect the data when you input your details for subscription purposes.
The Personal Information is processed for the purpose of informing you regularly by means of a newsletter or other offer form. The personal information collected during the subscription will only be used for marketing materials or for reasons made known on the form.
The legal basis for this processing is based on:
By submitting the form and voluntarily providing us with your data, you are providing consent to the use of such data by us for the purpose of providing subscription based materials. For the purpose of revocation of consent there is a corresponding unsubscribe link found in each subscription email. You also contact us at [email protected] to revoke your consent. Please review the consent section above in this Privacy Notice for how we deal with consent. Where we use your data for direct marketing, we will ensure that it is in compliance with relevant laws. Where you are a customer of ours, we may be required to send you emails for legitimate reasons including but not limited to billing, reminders and account verification.
We retain information on your behalf, such as domain names, URLs, time zone preferences, Service invoices, transactional history, messages and any other information that you store using your Account.
We may also collect Personal Information at other points on our Services. These points state that Personal Information is being collected. In some circumstances, Personal Information is provided to us by third parties such as our related entities, service providers or other organisations conducting activities on your behalf. With your express consent, your Personal Information may be used and disclosed to us this way. The purposes as outlined above may include the processing of such Personal Information to the extent necessary for us to comply with a law, regulation or legal request or to protect the safety of any person or to prevent fraud.
Some of our Services may allow you to add or may have metadata added to your content such as geotags (to mark your location), comments or other data. This helps our Services and your content to be more searchable.
We use location data to help target and tailor the Services to your particular location and jurisdiction. With your consent, we may also collect information about your precise location using methods including wireless networks, Wi-Fi access points and other sensors.
To make our Services more useful to you, our servers (which may be hosted by a third-party service provider) gather information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyse trends, to administer the Services, to learn about user behaviour regarding the Services, to improve our product and services, and to gather demographic information about our user base as a whole. Strength By Numbers may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on our Services. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
We use third party analytics tools to collect information anonymously and report website trends without identifying individual visitors. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving the Services.
We may also collect information and communications that other people provide when they use our Services. This can include information about you such as when others send messages, documents and information to you. If you are an employee of a business, this might include information that your employer provides to us. We may also collect your information if you are invited to participate in our Services. This may include information such as your name, phone number and email address relevant to the Services and is used for the purpose of enabling us to provide our Services to you.
We will only collect information about you directly from you, except where it is unreasonable or impracticable to do so.
We will only use or disclose your personal information for the purposes for which we advised you we were collecting it as noted in this Privacy Notice and including to:
We agree to not use or disclose this information for a secondary purpose unless you consent to us doing so, or another exception applies under applicable laws.
For the purposes of the law, some information we hold about you may be considered 'sensitive' as a special category of data and therefore subject to greater protection. In the event that we hold sensitive information about you, we will only disclose or use that information with your consent or if another exception applies under applicable laws.
We will also use or disclose your personal information or special category data if we are required to do so by law or a court / tribunal order, or if we reasonably believe that the use or disclosure of the information is reasonably necessary for an enforcement related activity or on behalf of an enforcement body, in which case we will make a written note of the use or disclosure or another exception applies under relevant laws.
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose.
We may collect information:
This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and Services are of most interest, and for the purpose of providing and improving our Services and assessments of end users’ strength and movement. Aggregated data is considered non-personal information for the purposes of this Privacy Notice.
We regularly review the anonymised data to ensure that any risk of possible re-identification of individuals is as minimised as possible.
We may disclose your Personal Information to third parties for the purposes contained in this Privacy Notice, including without limitation to:
We may share your Personal Information with service providers to:
The service providers (and if necessary, data processors) include:
These third party service providers are required not to use your Personal Information other than to provide the services requested by Strength By Numbers. If you would like to see a list of our service providers, please see our list of sub-processors https://www.strengthbynumbers.com/pages/list-of-subprocessors (Sub-processor List).
We may share some or all of your Personal Information with any of our parent companies’ subsidiaries, joint ventures, or other companies under a common control (Affiliates), in which case we will require our Affiliates to honour this Privacy Notice. In the event we are involved in a merger, acquisition or sale of assets we may disclose Personal Information collected by us to such entities that we propose to merge with or be acquired by and will assume the rights and obligations regarding your Personal Information as described in this Privacy Notice. This includes the disclosure of information to our clients where we act as a data processor.
We may disclose your Personal Information to third parties to whom you expressly ask to us to send the Personal Information to or to third parties you choose to send your Personal Information to.
We may also, with your consent or at your direction, disclose your personal information to your authorised representatives.
Regardless of any choices you make regarding your Personal Information (as described below), Strength By Numbers may disclose Personal Information if it believes in good faith that such disclosure is necessary:
We may share your Personal Information with such third parties subject to obligations consistent with this Privacy Notice and any other appropriate confidentiality and security measures, and on the condition that the third parties use your Personal Information only on our behalf and pursuant to our instructions.
We will take reasonable steps to ensure that anyone to whom we disclose your personal information respects the confidentiality of the information and abides by the EU GDPR, UK GDPR or equivalent privacy laws.
We will not share, sell, rent or disclose your personal information in ways different from what is disclosed in this Privacy Notice.
If you do not provide us with the Personal Information described above, some or all of the following may happen:
A cookie is a small piece of text sent to your browser by a website that you visit. It helps the website to remember information about your visit, like your preferred language and other settings. That can make your next visit easier and the site more useful to you. Cookies play an important role. Without them, using the web would be a much more frustrating experience.
Strength By Numbers’ Services, including websites, online services, email messages, and advertisements, may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behaviour, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.
We generally treat information collected by cookies and other technologies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Notice.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
Some people prefer not to allow cookies, which is why most browsers give you the ability to manage cookies to suit you. If you want to disable cookies, you may do so using the function in your web browser. Please note that certain features of the Strength By Numbers Services may not be available once cookies are disabled.
When you click on a link to any other website or location, you will leave our website and go to another site and another entity may collect Personal Information or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Notice do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.
Subject to the EU GDPR or UK GDPR, you may request to access the Personal Information we hold about you by contacting us. All requests for access will be processed within a reasonable time.
We may, if required, provide you with tools and account settings to access, correct, delete, or modify the Personal Information you provided to us. You can find out more about how to do this by contacting us. In the event that you are unable to access your Account to access or rectify your Personal Information, you may submit a request to us to correct, delete or modify your Personal Information and download the data for you.
We keep data for as long as it is needed for our operations. If you deactivate and delete your Account, your data will no longer be visible on your Account. Please keep in mind that third parties may still retain copies of information you have made public through our Services.
If you wish to have us delete your data, please contact us.
You may submit a request to us if you object to any Personal Information being stored, or if you wish to restrict or withdraw any consent given for the collection of your Personal Information.
You may withdraw your consent to the processing of all your Personal Information at any time. If you wish to exercise this right, you may do so by contacting us.
You may withdraw your consent or manage your opt-ins by either viewing your account on the Services or clicking the unsubscribe link at the bottom of any marketing materials we send you.
We may, if required and possible, provide you with the means to download the information you have shared or generated through our services. Please contact us for further information on how this can be arranged.
In certain instances, we may not be required or able to provide you with access to your Personal Information. If this occurs, we will give you reasons for our decision not to provide you with such access to your Personal Information in accordance with the requirements of the EU GDPR or UK GDPR.
There is no application fee for making a request to access your personal information. However, we may charge an administrative fee for the provision of information in certain circumstances, such as if you make repeated requests for information or where the information is held by a third-party provider.
Where we act as a data processor, we do so on behalf of our customer and in accordance with their instructions. This means that should you wish to access, review, correct, transfer, modify or delete any Personal Information we process on behalf of a customer you should contact the customer with your request.
Strength By Numbers stores Personal Information in our Services as well as with some of our sub-processors in our Sub-processor List.
Strength By Numbers takes the security of your personal information very seriously. We will take all steps reasonable under the circumstances to protect your personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. We will process Personal Information securely and apply and maintain appropriate technical and organisational measure to protect Personal Information.
The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Notice.
Where we transfer Personal Information from within to outside of the EU, EFTA States or UK, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws.
We may disclose Personal Information to our related bodies corporate and third-party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your Personal Information do not breach the privacy obligations relating to your Personal Information.
We may disclose your Personal Information to entities located outside of Australia, including the following:
We may disclose your Personal Information to entities within Australia who may store or process your data overseas.
We take data breaches very seriously.
We will endeavour to meet the 72-hour deadline as imposed by the EU GDPR and UK GDPR, to report any data breach to the supervisory authority or to the Information Commissioner’s Office where a data breach occurs that will likely be a risk to you.
Further, where there is likely to be a high risk to your rights, we will endeavour to contact you without undue delay. We will review every incident and take action to prevent future breaches.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision is not necessary for entering into, or the performance of, a contract between us, or is not authorised by Union or Member State law or UK law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or is not based on your explicit consent. If you wish to exercise your rights, please contact us.
We take all reasonable steps to ensure that the Personal Information we collect about you is accurate, up to date and complete. Where we collect that information from you directly, we rely on you to supply accurate information. Strength By Numbers makes it easy for you to keep your Personal Information accurate, complete, and up to date. Where we use or disclose your Personal Information, we will also ensure that your Personal Information is relevant.
We will retain your Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. We may retain your information for fraud prevention or similar purposes.
Strength By Numbers welcomes your comments or questions regarding this Privacy Notice.
If you have a question regarding this Privacy Notice or you would like to make a complaint, please contact us by email by using the details below.
If you reside in the EU, EFTA States, or the UK, the data controller that is responsible for your Personal Information is:
SBN Technology Pty Ltd
ACN 624 009 598
Email: [email protected]
Address: 18/328 Reserve Road
Cheltenham, Victoria, 3192
For individuals based in the UK, we have appointed Prighter Ltd as our Article 27 representative under the UK GDPR. If you want to exercise your rights under the UK GDPR, please visit https://prighter.com/q/17972569608.
To contact our UK Article 27 representative, please use the details below:
c/o SBN Technology Pty Ltd
Email: [email protected]
Address: Prighter Ltd (UK) 20 Mortlake Mortlake High Street London SW14 8JN United Kingdom
Please add the following subject to all correspondence: ID-17972569608
If you wish to raise a concern about our use of your information you have the right to do so with your local supervisory authority for individuals based in the EU or with the Information Commissioner’s Office for individuals based in the UK.
This Privacy Notice is subject to occasional revision and Strength By Numbers reserves the right, at its sole discretion, to modify or replace any part of Privacy Notice. It is your responsibility to check the Privacy Notice periodically for changes. Continued use of our Services including the website shall indicate your acknowledgement of that it is your responsibility to review the Privacy Notice periodically and become aware of any modifications.
We may amend this Privacy Notice from time to time. Not all changes to our Privacy Notice will require your consent, for example where office security procedures are changed. We will notify you of any change to our information handling policy that requires your consent before being implemented.